What is the standard for proving a waiver of the right to counsel?

The right to counsel is not specifically addressed in any statutes exempted by the "truth in evidence law." It is not addressed in Ramona R. The federal standard for measuring proof of voluntariness of a waiver of the right to counsel is clear. Lego v. Twomey, supra, 404 U.S. 477, 92 S.Ct. 619, requires that voluntariness be proved by a preponderance of the evidence. Application of the California standard, articulated in Jimenez, would require proof beyond a reasonable doubt and would result in exclusion of evidence which would be admissible under federal law.