California, United States of America
The following excerpt is from The People v. Brunson, Los Angeles County Super. Ct. No. NA079895, No. B219737 (Cal. App. 2010):
6. "[Code of Civil Procedure section 284] is applicable to criminal cases." (Mandell v. Superior Court (1977) 67 Cal.App.3d 1, 4, citing In re Haro (1969) 71 Cal.2d 1021, 1029.)
7. Under these circumstances, the trial court would not be expected to discharge counsel.
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