The following excerpt is from United States v. Brown, 785 F.3d 1337 (9th Cir. 2015):
The government maintains that, in cases like this one, as in Martel v. Clair, the factors relevant to the appointment of counsel issue are the timeliness of the motion; the adequacy of the district court's inquiry into the defendant's complaint; and the asserted cause for that complaint, including the extent of the conflict or breakdown in communication between lawyer and client (and the client's own responsibility, if any, for that conflict).
[785 F.3d 1346]
Martel v. Clair, U.S. , 132 S.Ct. 1276, 1287, 182 L.Ed.2d 135 (2012).
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