How have courts interpreted a waiver of Sixth Amendment rights in a civil case?

[218 Cal.App.3d 584] The people have cited Patterson v. Illinois (1988) 487 U.S. 285, 108 S.Ct. 2389, 101 L.Ed.2d 261 as "instructive," since that court noted, in the context of a waiver of Sixth Amendment rights, that the key inquiry must be: "Was the accused, who waived his Sixth Amendment rights duringpostindictment questioning, made sufficiently aware of his right to have counsel present during the questioning, and of the possible consequences of a decision to forego

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