not filed in a case, the rebuttable presumption is that it was considered by the appellant and rejected.” Oldham v. State, 977 S.W.2d 354, 363 (Tex.Crim.App.1998). Although Gallegos contends no reasonable attorney would forego filing a motion for new trial when the motion was truly meritorious, we can just as easily presume counsel conferred with his client and discovered the text message was favorable to Gallegos. Because Gallegos has failed to establish the first Strickland prong, he cannot prevail on his claim of ineffective assistance of counsel. Gallegos’s fifth issue on appeal is therefore overruled. Cumulative Error Finally, Gallegos urges this court to consider the cumulative impact of the errors presented above. See Chamberlain v. State, 998 S.W.2d 230, 238 (Tex.Crim.App.1999) (<HOLDING>). Because we have overruled all but one of
holding that cumulative  effect of multiple errors worked to deprive defendant of fair trial although  some errors standing alone would be subject to plain error review and others might be harmless holding that the combined effect of trial counsels errors should be considered holding that counsel cannot be deemed ineffective for failure to present cumulative evidence holding that although neither of the trial courts errors when considered in isolation were necessarily sufficiently prejudicial to require a new trial the cumulative effect of the errors created sufficient prejudice to deny defendant a fair trial holding that a number of errors may be deemed harmful in their cumulative effect