Prisoner Certification Proved Timely Mailing

Brown v. Leavenworth County, Kansas, 2009 WL 1132358 (4/28/09) (unpub'd) - The prisoner satisfied proof of timely mailing by certifying he used the prison's internal legal mail system. A declaration under penalty of perjury or a notarized statement regarding mailing is not required when the prisoner certifies he used the prison's legal mail system.