The following excerpt is from Gonzalez-Plascencia v. United States, CASE NO. 1:12-CR-277 AWI DLB (E.D. Cal. 2015):
Despite a waiver of the right to appeal or file a collateral attack, claims of ineffective assistance of counsel that challenge the voluntariness of a plea may still be brought in a collateral proceeding. See United States v. Brizan, 709 F.3d 864, 867 (9th Cir. 2013); Washington v.
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