What is the effect of a waiver of a plaintiff's right to counsel de novo?

MultiRegion, United States of America

The following excerpt is from United States v. Ferrer, No. 17-2303 (2nd Cir. 2019):

We review the circumstances surrounding Ferrer's waiver of his right to counsel de novo. See United States v. Spencer, 995 F.2d 10, 11 (2d Cir. 1993).

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