Does a substitution of attorney have to apply for a motion for a new trial?

California, United States of America


The following excerpt is from People v. Gibbons, H040527 (Cal. App. 2015):

8. The substitution of attorney was filed on August 1, 2013. The hearing on the motion for new trial was held on November 5, 2013. Thus, defense counsel had ample time to determine former counsel's position as to defendant's claims.

9. People v. Marsden (1970) 2 Cal.3d 118.

10. All further statutory references are to the Penal Code unless otherwise stated.

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