What is considered "advisory counsel" in a personal injury case?

In California, a waiver of a defendant's right to counsel is not implied from a defendant's mere participation in his defense; there must be an explicit waiver of his right to counsel and advisement of the consequences of his decision to represent himself, including the inability to raise ineffective assistance of counsel on appeal. (See People v. Spencer (1984) 153 Cal.App.3d 931, 945, 200 Cal.Rptr. 693; People v. Lopez (1977) 71 Cal.App.3d 568, 572, 138 Cal.Rptr. 36.)

2 While the two terms ("standby" and "advisory") are often used interchangeably, the court in People v. Kurbegovic (1982) 138 Cal.App.3d 731, 757-758, 188 Cal.Rptr. 268, distinguished between them: "[T]he term 'standby' counsel generally relates to an attorney's being present to step in and represent an individual no longer able to represent himself,.... [p] 'Advisory' counsel, however, generally refers to an attorney who assists a litigant representing himself in a variety of ways,...."