California, United States of America
The following excerpt is from People v. Ramirez, E057173 (Cal. App. 2014):
During the July 25, 2012 hearing, defendant's attorney requested a trial continuance. In response, defendant complained that a courtroom had not been available on June 12 to hold a Marsden hearing and that he was annoyed with his attorney and the trial delays. Defendant, however, did not make an unequivocal request for a new attorney or request a Marsden hearing. (People v. Dickey (2005) 35 Cal.4th 884, 920.) "'"Although no formal motion is necessary, there must be 'at least some clear indication by defendant that he wants a substitute attorney."' [Citations.]" (Ibid.)
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