California, United States of America
The following excerpt is from People v. Mitchell, A133094 (Cal. App. 2014):
defendant's motion was directly tied to the delay and disruption that inevitably would have flowed from granting it. The court did not abuse its discretion. (See People v. Turner, supra, 7 Cal.App.4th at pp. 915-916, 918-919 [court's denial of belated request to discharge counsel proper because the request was unduly disruptive to "witnesses and other participants"]; People v. Lau (1986) 177 Cal.App.3d 473, 477-479 [denial of substitution based on disagreement between counsel and client regarding defendant's guilt or innocence, though resulting in a loss of trust on the part of the client and anger on the part of the attorney, was justified by the lateness of the request].)
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