The following excerpt is from United States v. Murdock, 12-4382 (2nd Cir. 2013):
We review a district court's decision not to substitute counsel for abuse of discretion. See United States v. Simeonov, 252 F.3d 238, 241 (2d Cir. 2001). "To determine whether the trial court abused its discretion, we consider: (1) the timeliness of defendant's request for new counsel; (2) the adequacy of the trial court's inquiry into the matter; (3) whether the conflict resulted in a total lack of communication between the defendant and his attorney; and (4) whether the defendant's own conduct contributed to the communication breakdown." United States v. Carreto, 583 F.3d 152, 158 (2d Cir. 2009).
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