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1 themselves we could just tell the judge.
2 Strickland talks about counsel has a duty to make
3 reasonable investigations or make a reasonable decision that
4 makes particular investigation unnecessary. And if ever there
5 was a reason either to investigate more, to unleash the
6 Nardello firm, or, I say this respectfully, unleash the Court.
7 Because as crazy as this woman was, I've always thought if your
8 Honor brought her out and said are you the same person, I'm not
9 sure her lying would have gone that far. You may disagree with
10 me on that, but I think she would have had trouble there.
11 But nobody does it. And nobody does it not because
12 they were playing a strategic game that they were out to
13 sandbag a court or they were out to get an acquittal. They
14 didn't do it because, to use the Second Circuit's word, it was
15 an oversight, it was careless, it was inept. And if I'm right
16 about that, then I think one has met the first prong here, and
17 then the question becomes prejudice.
18 And I can talk more, your Honor, the government
19 doesn't argue sandbagging. I can talk more about why I think
20 this wasn't -- look, I've read the Court's opinion, I think
21 only seven times. And I know that the Court at the end of it
22 talks about gambling. But, I don't think the Court is making
23 findings in that opinion that there was a great strategy going
24 on in that court. I think your Honor's findings are that these
25 people really dropped the ball, and they failed to do what they
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