California, United States of America
The following excerpt is from People v. Bumanglag, E052422 (Cal. App. 2012):
We have therefore considered whether the trial court should have admitted the medical records under Evidence Code section 1562; if so, then arguably defense counsel's otherwise ineffective assistance was not prejudicial. (See Lockhart v. Fretwell (1993) 506 U.S. 364, 369-371 [113 S.Ct. 838, 122 L.Ed.2d 180].)
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