The following excerpt is from Munoz v. Hubbard, CASE NO. 11-CV-2321-H (S.D. Cal. 2012):
Saffold, 536 U.S. 214, 221-25 (2002) (explaining that under California's "original writ" system, habeas petitions are "pending" for purposes of AEDPA during reasonable time periods between when a lower state court renders its habeas decision and when the petitioner files a habeas petition in a higher state court); Dils v. Small, 260 F.3d 984, 986 (9th Cir. 2001) (ruling that AEDPA's limitations period was not tolled between successive petitions in the same court).
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