California, United States of America
The following excerpt is from People v. Beal, B260599 (Cal. App. 2016):
Appellant's profanity-laden insults to the court after it denied his request provide further evidence he was simply upset over the court's refusal to continue sentencing. We conclude the trial court did not abuse its discretion by denying appellant's untimely motion to represent himself. (Cf. People v. Doolin (2009) 45 Cal.4th 390, 452, 454-455, fn. 39.)
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