California, United States of America
The following excerpt is from People v. Brown, B270677 (Cal. App. 2017):
It is apparent from the record the trial judge considered the factors described in People v. Jenkins, supra, 22 Cal.4th at page 959. She acknowledged the quality of counsel's representation, defendant's more than three-year history of going back and forth concerning representation, the late stage of the proceedings, and defendant's history of disrupting proceedings. No more was required. There was no abuse of discretion.
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