What is the test for a right of counsel in a personal injury case?

[(1982)] 30 Cal.3d [606,] 613-614.) The right to such counsel 'must be carefully weighed against other values of substantial importance, such as that seeking to ensure orderly and expeditious judicial administration, with a view toward an accommodation reasonable under the facts of the particular case.' (People v. Byoune [(1966)] 65 Cal.2d [345,] 346.)" (Courts, supra, 37 Cal.3d at p. 790.)