The following excerpt is from United States v. Schaefer, 19-30266 (9th Cir. 2021):
[5] In contrast to the phrases "counsel" and "counsel to represent" the defendant, which we use interchangeably here, the term "standby counsel" describes "the situation when a pro se defendant is given technical assistance by an attorney in the courtroom, but the attorney does not participate in the actual conduct of the trial." United States v. Salemo, 81 F.3d 1453, 1464 (9th Cir. 1996).
[6] The Government does not challenge that holding.
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