The following excerpt is from Boardman v. Estelle, 957 F.2d 1523 (9th Cir. 1992):
A criminal defendant must expressly and unequivocally waive his Sixth Amendment right to counsel in order to invoke his right to self-representation. Adams v. Carroll, 875 F.2d 1441, 1444 (9th Cir.1989). When a defendant equivocates, he is presumed to have requested the assistance of counsel because exercising the right to self-representation is generally believed to be
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