The following excerpt is from Reumont v. Ylst, 990 F.2d 1259 (9th Cir. 1993):
"[I]n order to invoke the Sixth Amendment right to self representation, the request must be (1) knowing and intelligent, (2) unequivocal, (3) timely, and (4) not for purposes of delay." United States v. Schaff, 948 F.2d 501, 503 (9th Cir.1991) (citations omitted). A request for self representation is timely if made before meaningful trial proceedings have begun, prior to jury selection, or if made before the jury is empaneled. Id.
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