What is the test for abuse of a motion to substitute counsel?

MultiRegion, United States of America

The following excerpt is from U.S. v. Fisher, 133 F.3d 929 (9th Cir. 1997):

We review for abuse of discretion the district court's denial of a motion to substitute counsel. See United States v. Ono, 997 F.2d 647, 650 (9th Cir.1993). Our inquiry focuses on the timeliness of the motion, the adequacy of the court's inquiry into the defendant's reasons, and whether there was a lack of communication between the defendant and his counsel that impeded the defense. See id.

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