Does a defendant have a right to counsel in a "critical stage" of a criminal proceeding?

The right to counsel under the Sixth Amendment applies to all critical stages of a criminal prosecution. (Iowa v. Tovar (2004) 541 U.S. 77, 80-81; People v. Ebert (1988) 199 Cal.App.3d 40, 44.) " 'The determination whether the hearing is a "critical stage"

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requiring the provision of counsel depends . . . upon an analysis "whether potential substantial prejudice to defendant's rights inheres in the [particular] confrontation and the ability of counsel to help avoid that prejudice." ' " (People v. Ebert, supra, at p. 44.) "[T]he essence of a 'critical stage' is . . . the adversary nature of the proceeding, combined with the possibility that a defendant will be prejudiced in some significant way by the absence of counsel." (U.S. v. Leonti (9th Cir. 2003) 326 F.3d 1111, 1117.)