Is ineffective assistance of counsel a valid claim?

Matta's ineffective assistance of counsel claim is also meritless. To begin with, "ineffective assistance claims are ordinarily reviewed only in collateral proceedings because such claims usually cannot be resolved without the development of facts outside the original record." United States v. Sitton, 968 F.2d 947, 960 (9th Cir.), cert. denied, 113 S.Ct. 478 (1992), and cert. denied, 113 S.Ct. 1306 (1993).

In any event, Matta does not cite a single error of counsel as a result of the delay, a failure which is fatal to his claim. See Strickland v. Washington, 466 U.S. 668, 687, 690 (1984).

B. The Spanish Wiretaps