California, United States of America
The following excerpt is from People v. Fitzpatrick, 66 Cal.App.4th 86, 77 Cal.Rptr.2d 634 (Cal. App. 1998):
In People v. Clark the pro se defendant, who had been cross-examining a prosecution expert witness, refused to resume cross-examination and said he would remain mute for the rest of the trial. The court revoked his pro se status and had standby counsel resume the cross-examination for the remainder of the day. The next day, defendant having had a change of heart, the court reinstated his pro se status.
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