California, United States of America
The following excerpt is from People v. Harbolt, 206 Cal.App.3d 140, 253 Cal.Rptr. 390 (Cal. App. 1988):
The burden is on Harbolt to demonstrate that he did not intelligently and knowingly waive his right to counsel. (People v. Mellor (1984) 161 Cal.App.3d 32, 37, 207 Cal.Rptr. 383.) Harbolt has not met this burden.
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