What is the test for reappointment of counsel to a defendant who is representing himself?

Generally, when a defendant who is representing himself requests the reappointment of counsel, the court must exercise its discretion by considering "'the totality of the facts and circumstances.'" (People v. Gallego (1990) 52 Cal.3d 115, 164.) Some of the relevant factors to consider are: "'(1) defendant's prior history in the substitution of counsel and the desire to change from self-representation to counsel-representation, (2) the reasons set forth for the request, (3) the length and stage of the trial proceedings, (4) disruption or delay which reasonably might be expected to ensue from the granting of such motion, and (5) the likelihood of defendant's effectiveness in defending against the charges if required to continue to act as his own attorney . . . .' [Citation.]" (Ibid.) "'While the consideration of these criteria is obviously relevant and

Page 7