What is the current state of the law on waiver of jury representation?

4 We draw this line only for cases like the one before us where the fact of a bench trial gives no notice that a jury issue may be being tried as well. Obviously, different considerations apply where an ongoing bench trial gives notice that a jury trial will not be held. See White v. McGinnis, 903 F.2d 699 (9th Cir.1990) (holding that silence in such circumstances may mandate finding of waiver of jury demand). We determine only under what circumstances a party may voluntarily withdraw its jury demand, not the circumstances under which a party's demand may be deemed to have been involuntarily waived.