CHIN, J.
The Sixth Amendment to the United States Constitution (Sixth Amendment) provides in part that "[i]n all criminal prosecutions, the accused shall enjoy the right ... to have the assistance of counsel for his defense." This right to counsel attaches "`at or after the initiation of adversary judicial criminal proceedings—whether by way of formal charge, preliminary hearing, indictment, information, or arraignment.' " (United States v. Gouveia ...
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