California, United States of America
The following excerpt is from People v. Hicks, H043000 (Cal. App. 2017):
7. At the outset, defendant requested that his counsel be discharged and that he be permitted to represent himself at the parole violation hearing. The court held a Marsden hearing (People v. Marsden (1970) 2 Cal.3d 118) and denied defendant's motion to discharge counsel.
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