When a defendant waives his right to testify in a civil trial, does that waiver need to be explicit or explicit?

However, while waiver of the right to testify must be knowing and voluntary, it need not be explicit. See id. Rather, a defendant is "presumed to assent to his attorney's tactical decision not to have him testify." Id. "[W]aiver of the right to testify may be inferred from the defendant's conduct and is presumed from the defendant's failure to testify or notify the court of his desire to do so." Id. A defendant who wishes to reject his attorney's advice and take the stand may do so "by insisting on testifying, speaking to the court, or discharging his lawyer." Id. When a defendant remains "silent in the face of his attorney's decision not to call him as a witness," he waives the right to testify. United States v. Nohara, 3 F.3d 1239, 1244 (9th Cir. 1993).