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Name: People v. Richardson
Case #: B164991
Court: CA Court of Appeal
District 2 DCA
Division: 2
Opinion Date: 04/06/2004

The court did not err in failing to appoint counsel at sentencing when the defendant attempted to withdraw his waiver of counsel. The defendant represented himself at trial, and at the end of proceedings filed a motion for new trial citing his own errors. The court denied that motion, and subsequently also denied the defendant’s request for counsel at sentencing. The Court of Appeal held that this was not an abuse of discretion, since the request was made late in the proceedings and appeared to be the product of hindsight.