Kovacs v. U.S., 744 F.3d 44, 51-52 (2d Cir. Mar. 3, 2014) (Prejudice can arise under Frye if a petitioner can demonstrate a reasonable probability [he] would have accepted the earlier plea offer had [he] been afforded effective assistance of counsel. Id. at 1409. In addition, a petitioner must show a reasonable probability that the end result of the criminal process would have been more favorable by reason of a plea to a lesser charge or a sentence of less prison time. Id.); citing Missouri v. Frye, ___ U.S. ___ 132 S.Ct. 1399, 1409, 182 L.Ed.2d 379 (2012).

 

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