The issuance of an arrest warrant and extradition proceedings against the defendant did not trigger his right to counsel. The defendant moved to suppress statements he made to law enforcement officials in Utah after he was arrested and held pending extradition to California. He argued that questioning outside the presence of an attorney violated his Sixth Amendment right to counsel, a right that he argued was triggered by the issuance of a California arrest warrant, or in the alternative by the commencement of extradition proceedings. The court rejected both arguments, holding that neither proceeding was sufficient to trigger Sixth Amendment protections.