What is the test for a motion for substitution of counsel for abuse of discretion?

MultiRegion, United States of America

The following excerpt is from U.S. v. Tovar, 878 F.2d 1439 (9th Cir. 1989):

We review the district court's denial of a motion for substitution of counsel for abuse of discretion. United States v. Whaley, 788 F.2d 581, 583 (9th Cir.1986). We consider the timeliness of the motion, the adequacy of the district court's inquiry, and whether any attorney-client conflict was so great as to result in an inadequate defense. Id. See also United States v. McClendon, 782 F.2d 785, 789 (9th Cir.1986).

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