California, United States of America
The following excerpt is from People v. Armijo, B286698 (Cal. App. 2019):
"Furthermore, '[a] trial court is not required to conclude that an irreconcilable conflict exists if the defendant has not made a sustained good faith effort to work out any disagreements with counsel.'" (Myles, supra, 53 Cal.4th at p. 1207; see People v. Smith (2003) 30 Cal.4th 581, 606 ["[d]efendant did not show that
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defense counsel did anything to cause any breakdown in their relationship"]; People v. Barnett (1998) 17 Cal.4th 1044, 1086 [no abuse of discretion in denying defendant's Marsden motion where defendant sought substitute counsel only 13 days after counsel's appointment].)
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