Khan v. United States, No. 18-12629 (11th Cir. 2019)
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An attorney's disregard of a court instruction to obtain the official consent of a foreign government to conduct video depositions on its soil does not constitute ineffective assistance of counsel per se.
The Eleventh Circuit affirmed the district court's denial of defendant's motion to vacate his sentence. In this case, counsel's decision to disregard the court instruction to obtain formal approval constituted a choice dictated by reasonable trial strategy. Furthermore, defendant failed to establish that he was prejudiced by the inability of the witnesses to testify.
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