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ITEM 1.2.05 | DEADLINES RUNNING FROM SERVICE OF A DOCUMENT
Whenever a party is required or permitted to act within a prescribed period after service of a paper upon that party, three days are added to this prescribed period unless the paper is delivered on the date of service stated in the proof of service. Fed. R. App. P. 26(c). A paper that is served electronically is treated as delivered on the date of service; thus, three days are not added to deadlines running from electronic service of a document. Fed. R. App. P. 26(c) (effective Dec. 1, 2016).