Defendant first claims that counsel Armando Sierra was ineffective because he did not meet with defendant. Counsel's assistant, however, met with defendant on at least three occasions and accepted numerous phone calls from him. In addition, counsel testified that he had met with defendant at the jail. Given that this case was not complicated, we conclude that counsel's actions did not fall below an objective standard of reasonableness. We find this explanation a reasonable tactical decision and therefore conclude that no error occurred.
Defendant also attacks counsel's pretrial investigation.
He claims that counsel should have sought out the reputed owner of the car to testify. That motion, however, was filed by a counsel whom defendant later replaced with Sierra. Consequently, counsel had no reason to locate that individual. In addition, counsel did prepare for trial. The magistrate found that counsel effectively cross-examined the government's witnesses.