The following excerpt is from Gray v. Swarthout, No. CIV S-10-2463 JAM EFB P (E.D. Cal. 2011):
8. The court deems the filing date for of this petition to be the date reflected on the certificate of service. See Houstan v. Lack, 487 U.S. 266, 276 (1988) (prisoner's notice of appeal deemed timely filed on the date it was delivered to prison staff for delivery to the court).
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