The following excerpt is from Badger v. Cardwell, 587 F.2d 968 (9th Cir. 1978):
Most recently, in United States v. Kizer, 569 F.2d 504 (9th Cir. 1978), the defendant interrupted the prosecuting attorney's closing argument, demanded discharge of her attorney and a new trial, and continued to argue with the judge after her motions were denied. This court upheld the order to remove her.
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