The following excerpt is from Frye v. Warden, No. 2:99-cv-0628 KJM CKD (E.D. Cal. 2015):
"The Sixth Amendment right to counsel in a criminal trial includes 'the right to the effective assistance of counsel.'" Summerlin v. Schriro, 427 F.3d 623, 629 (9th Cir. 2005)
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