Does a motion for a new trial need to be heard at a Marsden hearing?

This court's recent decision in People v. Richardson (2009) 171 Cal.App.4th 479 supports our conclusion. In Richardson, the court held there was no error in failing to conduct a Marsden hearing "because a request for new trial based on a defendant's claim of ineffective assistance of counsel does not trigger the court's duty to conduct a Marsden hearing if the defendant's desire for substitute counsel is not made clear." (Id. at p. 484.) Here, defense counsel's pro forma assertion of ineffective assistance of counsel in the memorandum of points and authorities in support of the new trial motion did not, by any means, "ma[k]e clear" that defendant wanted substitute counsel.