The following excerpt is from U.S. v. Flewitt, 874 F.2d 669 (9th Cir. 1989):
A defendant may not invoke his right to self representation if it is used as a tactic to secure delay. Smith, 780 F.2d at 811; Fritz v. Spalding, 682 F.2d 782, 784 (9th Cir.1982). Here, defendants attempted to delay their trial on the merits by asserting their right to proceed pro se in an untimely manner and by refusing to comply with court procedure.
A. Timely Assertion of Pro Se Right
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