California, United States of America
The following excerpt is from Ap-Colton LLC v. Ohaeri, E059505 (Cal. App. 2015):
(Walker v. State Bar (1989) 49 Cal.3d 1107, 1116.) In any event, even a constitutional right can be waived or forfeited. Thus, even assuming that he had a constitutional right to appear through retained counsel, he forfeited it by choosing to proceed in propria persona until the very last minute before trial.
We therefore conclude that the trial court did not err by denying a continuance.
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