California, United States of America
The following excerpt is from People v. Terrell, 69 Cal.App.4th 1246, 82 Cal.Rptr.2d 231 (Cal. App. 1999):
"If the record contains no explanation for the challenged behavior, an appellate court will reject the claim of ineffective assistance 'unless counsel was asked for an explanation and failed to provide one, or unless there simply could be no satisfactory explanation.' " (People v. Kipp, supra, 18 Cal.4th at p. 367, 75 Cal.Rptr.2d 716, 956 P.2d 1169; citation omitted.)
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