Many DMs seem to ignore encumbrance anyway, so why worry about how many bags of holding are within their (main) bag of holding? I would just rule that if they attempted to open one whilst it was within another a "BAD THING" would happen, but otherwise they were fine - and would need a standard action or move action to remove the bag 1 from within bag 2 and then open it. As a swift action they could, of course, flip open the top of one, reach in, and flip up the top of another - and suffer the consequences, of course. On the other hand, perhaps there are times when they wouldn't mind being randomly plane shifted due to the resulting planar rift . . . .
Rope Trick and Handy Haversack
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