California, United States of America
The following excerpt is from People v. Fuentes, B231367 (Cal. App. 2012):
Here, defendant made his motion to represent himself after the trial commenced. The jury had been sworn5 and instructed by the trial court, and opening statements had been concluded. The trial court deemed the motion untimely, and it had the discretion to deny it. (People v. Howze (2001) 85 Cal.App.4th 1380, 1397.)
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