The following excerpt is from Deutscher v. Whitley, 884 F.2d 1152 (9th Cir. 1989):
In our efforts to protect the constitutional right to "effective assistance of counsel" recognized in McMann v. Richardson, 397 U.S. 759, 771 n. 14, 90 S.Ct. 1441, 1449 n. 14, 25 L.Ed.2d 763 (1970), we have often treated "ineffective assistance of counsel"
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