The following excerpt is from Taldybek Usubakunov v. Garland, 18-72974 (9th Cir. 2021):
Notwithstanding the importance of counsel, a noncitizen may knowingly and voluntarily waive the right to counsel and proceed pro se. See Mendoza-Mazariegos v. Mukasey, 509 F.3d 1074, 1080 (9th Cir. 2007). Usubakunov did not
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waive his right to counsel; rather, he plainly requested additional time to vindicate that right.
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