What is the test for intentionally eliciting incriminating statements from a defendant?

"The Sixth Amendment to the federal Constitution provides in pertinent part: 'In all criminal prosecutions, the accused shall enjoy the right . . . to have the Assistance of Counsel for his defence.' This right 'attaches' "'at or after the initiation of adversary judicial criminal proceedingswhether by way of formal charge, preliminary hearing, indictment, information, or arraignment.'" [Citation.] After it both attaches and is invoked, any incriminating statement the government deliberately elicits from a defendant in counsel's absence is inadmissible at that defendant's trial. [Citations.]' [Citation.]" "'"The question here is whether under the facts of this case a Government agent 'deliberately elicited' incriminating statements . . . within the meaning of Massiah [Massiah v. United States (1964) 377 U.S. 201]" . . . .' [Citation.] 'This inquiry is objective and does not focus on the subjective intentions of the state officer.' [Citation.]" (People v. Huggins (2006) 38 Cal.4th 175, 244-245 (Huggins).)