California, United States of America
The following excerpt is from People v. Aragon, E050645 (Cal. App. 2011):
"Although no formal motion is necessary, there must be 'at least some clear indication by defendant that he wants a substitute attorney.' [Citation.]" (People v. Mendoza (2000) 24 Cal.4th 130, 156 -157, italics added.) For example, the defense counsel in Dickey told the court following the guilt phase of trial that he and defendant had become embroiled in a disagreement over trial tactics, such as how certain matters should have been presented and what witnesses should have been called. To resolve their disagreements, counsel proposed to defendant and then to the court that separate counsel
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