California, United States of America
The following excerpt is from People v. Rittenhouse, C087020 (Cal. App. 2019):
defendant to represent himself would not have caused a delay. (See People v. Braxton (2004) 34 Cal.4th 798, 807, fn. 2 [trial court must entertain new trial motion even when not made in advance of a scheduled sentencing hearing and not made in writing].) Under these circumstances, it is apparent that defendant made his request within a reasonable time.
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