The following excerpt is from Owens v. Borg, 963 F.2d 379 (9th Cir. 1992):
In United States v. Pace, 833 F.2d 1307 (9th Cir.1987), cert. denied, 486 U.S. 1011 (1988), we clarified that the Sixth Amendment right to counsel does not attach at the time of detention. It attaches only upon (1) formal charge, (2) preliminary hearing, (3) indictment, (4) information, or (5) arraignment. Id. at 1310.
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