The following excerpt is from U.S. v. Washington, 855 F.2d 864 (9th Cir. 1988):
Turning to the facts before us, I agree that the district court could have informed Washington more fully of the dangers of self-representation. I dissent, however, because Washington constructively waived his right to counsel through dilatory tactics designed "to gain time or effect delay" in his proceedings. United States v. Kelm, 827 F.2d 1319, 1322 (9th Cir.1987).
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