To the extent that these and any other cases eliminate or dilute the "reasonable probability" standard set forth in Strickland, they are disapproved and will not be followed. See, e.g., Jowers v. State, 272 Ga. App. 614 (3) ( 613 SE2d 14) (2005); Lemming v. State, 272 Ga. App. 122 (2) ( 612 SE2d 495) (2005); Wright v. State, 265 Ga. App. 855 (1) ( 595 SE2d 664) (2004); Wiltshire v. State, 191 Ga. App. 426 (1) ( 382 SE2d 166) (1989); McAlister v. State, 204 Ga. App. 259 (2) ( 419 SE2d 64) (1992); Champion v. State, 238 Ga. App. 48 (1) ( 517 SE2d 595) (1999); Glore v. State, 241 Ga. App. 646 (3) ( 526 SE2d 630) (1999); Minter v. State, 245 Ga. App. 327 (6) ( 537 SE2d 769) (2000); Lewis v. State, 249 Ga. App. 812 (5) (b) ( 549 SE2d 732) (2001); Prins v. State, 246 Ga. App. 585 (5) ( 539 SE2d 236) (2000); Johnson v. State, 274 Ga. App. 69 (2) ( 616 SE2d 848) (2005); In the Interest of F. C., 248 Ga. App. 675 (3) ( 549 SE2d 125) (2001); Mahone v. State, 247 Ga. App. 596 (2) ( 544 SE2d 514) (2001); Peterson v. State, 253 Ga. App. 390 (5) ( 559 SE2d 126) (2002); Cortez v. State, 253 Ga. App. 699 (6) ( 561 SE2d 142) (2002). See Trimble v. State, 274 Ga. App. 536 (2) (b) ( 618 SE2d 163) (2005); Taylor v. State, 270 Ga. App. 637 (1) ( 607 SE2d 163) (2004); Shelley v. State, 239 Ga. App. 841 (4) ( 521 SE2d 855) (1999); Roberts v. State, 229 Ga. App. 783 ( 494 SE2d 689) (1997).

[Cit.]" Champion v. State, 238 Ga. App. 48, 49 (1) (b) 517 SE2d 595 (1999). Here, the tactical decision as to which requests to charge to submit was reasonable and provides no basis for a reversal of Lamar's conviction.

We cannot say, as a matter of law, that this trial strategy was unreasonable. See Champion v. State, 238 Ga. App. 48, 49 (1) (a) ( 517 SE2d 595) (1999). See generally Letson v. State, 236 Ga. App. 340, 341-342 (2) ( 512 SE2d 55) (1999).

Similarly, trial counsel's decisions as to the submission of requests to charge fall within the scope of trial tactics and strategy. Champion v. State, 238 Ga. App. 48, 49(1)(b) ( 517 S.E.2d 595) (1999). Moreland's trial counsel testified that his tactical focus on the common law marriage issue was "not for the jury so much as" that he was attempting to persuade the trial court "that there was a common law marriage there because I wanted to — my theory there, what I was attempting to do, was to give the victim in this case, who was the common law wife of Mr. Moreland, the opportunity to back out of giving testimony under the marital privilege.

" We cannot say that failure to request a charge on a lesser included offense was patently unreasonable in this case. (Citation omitted) Champion v. State, 238 Ga. App. 48, 49(1)(b) ( 517 S.E.2d 595) (1999). (g) Lovelace also claims ineffective assistance because his trial counsel failed to object to Lovelace's exclusion from the courtroom during jury selection and because trial counsel failed to object after a juror sent the trial court a note requesting an explanation as to why Lovelace was on Thornton's property.

(Citation omitted.) Champion v. State, 238 Ga. App. 48, 49(1)(b) ( 517 S.E.2d 595) (1999). Furthermore, "[i]n the absence of testimony to the contrary, counsel's actions are presumed strategic."

As defense counsel's decision was a matter of trial tactics and strategy, and Berry does not show that no competent attorney would have chosen this course of action, Berry fails to establish that he received ineffective assistance of counsel. (Citation omitted) Champion v. State, 238 Ga. App. 48, 49(1)(b) ( 517 S.E.2d 595) (1999). (b) Berry also claims that he received ineffective assistance of counsel because his attorney was not prepared for trial. This claim has no merit. Berry does not support this argument other than by showing that he expressed his dissatisfaction with his attorney immediately before trial. Because Berry does not point to any instances in the record that reflect a lack of preparedness on the part of his defense counsel, Berry has not shown that he received ineffective assistance of counsel.

Under these circumstances, Lockett cannot establish that he was prejudiced by his attorney's failure to seek a contemporaneous limiting instruction. See Champion v. State, 238 Ga. App. 48, 49(1)(b) ( 517 S.E.2d 595) (1999) (counsel's failure to seek contemporaneous limiting instruction on similar transaction evidence not ineffective assistance when principle covered in general charge). (b) According to Lockett, his trial attorney rendered ineffective assistance for failing to seek suppression of his statement.

(Citation omitted.) Champion v. State, 238 Ga. App. 48 (1) ( 517 S.E.2d 595) (1999). Although Jackson's trial counsel testified at the motion-for-new-trial hearing, Jackson's appellate counsel did not ask him about his reasoning for not requesting the specified lesser charges.

They provide no grounds for reversal unless such tactical decisions are so patently unreasonable that no competent attorney would have chosen them. [Cit.]" Champion v. State, 238 Ga. App. 48, 49 (1) (b) ( 517 S.E.2d 595) (1999). So viewing trial counsel's failure to object, we cannot agree that her failure to object constituted deficient performance, especially given our holding in Ellis, supra, that it is not error to fail to define the term "maliciously" as it applies to the offense of aggravated battery.