o be sure, as the Government points out, effective defense counsel should always explore plea bargaining opportunities. See Gov't Resp. at 7 (citing Padilla v. Kentucky, 130 S.C.t 1473, 1485 (2010)). But this is a far cry from proving there is a "right" to plea bargaining or that protecting plea bargaining opportun

t the negotiation of a plea bargain is a critical phase of litigation for purposes of the Sixth Amendment right to effective assistance of counsel." Padilla v. Kentucky, U.S. 130 S. Ct. 1473, 1485 (2010) (citation omitted). This includes the "critical obligation of counsel to advise the client of `the advantages a

t the negotiation of a plea bargain is a critical phase of litigation for purposes of the Sixth Amendment right to effective assistance of counsel." Padilla v. Kentucky, U.S. 130 S. Ct. 1473, 1485 (2010) (citation omitted). This includes the "critical obligation of counsel to advise the client of `the advantages a