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P. v. Orduno CA2/4
Appellant Santos Orduno retained private counsel to defend him against murder, attempted murder, and burglary charges. Over two years later, immediately before jury selection and the beginning of trial, Orduno requested to discharge private counsel and represent himself. The following day, Orduno clarified that he wished to discharge his private counsel and be defended by court-appointed counsel. The trial court denied these requests as

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