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PEOPLE v. BRUNO

11014.

180 A.D.3d 496 (2020)

119 N.Y.S.3d 455

2020 NY Slip Op 01014

The People of the State of New York, Respondent, v. Justin Bruno, Appellant.

Appellate Division of the Supreme Court of New York, First Department.

Decided February 13, 2020.

Defendant's expressions of dissatisfaction with his third assigned attorney, near the end of the trial, and his declaration that he was hiring private counsel, did not constitute a "seemingly serious request" for new counsel, and thus the court was not required to make a "minimal inquiry" (People v Porto, 16 N.Y.3d 93, 100 [2010]). While the court did not make a direct inquiry, and expressed its inclination to deny any substitution...

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