What steps must be taken by counsel to establish that counsel is ineffective representation in a civil case?

"New York", United States of America

The following excerpt is from People v. Gross, 2016 N.Y. Slip Op. 01204, 26 N.Y.3d 689, 27 N.Y.S.3d 459, 47 N.E.3d 738 (N.Y. 2016):

testimony. Counsel did not take these necessary minimal steps, and as a consequence her representation was ineffective, and denied defendant a fair trial (People v. Baldi, 54 N.Y.2d 137, 444 N.Y.S.2d 893, 429 N.E.2d 400 [1981] ).

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