Memorandum:
Defendant has not demonstrated that he was deprived of a fair trial by less than meaningful representation. "[A] simple disagreement with strategies, tactics or the scope of possible cross-examination, weighed long after the trial, does not suffice" to satisfy defendant's burden of establishing ineffective assistance of counsel ( People v Flores, 84 NY2d 184, 187; see, People v Benn, 68 NY2d 941, 942). (Appeal from Judgment of Jefferson County Court, Clary, J. — Rape, 1st Degree.)