We conclude that the district court did not abuse its discretion by determining that appellant had forfeited his right to an attorney by attacking his public defender in open court. No court can carry on its business in an atmosphere of violence, fear, and intimidation. Id. at 82 (footnote omitted). Consistent with Lehman, other jurisdictions have held that a defendant forfeits his right to counsel when he physically attacks or assaults his counsel. See Gilchrist v. O’Keefe, 260 F.3d 87, 90, 99-100 (2d Cir.2001) (ruling that a habeas petitioner had not been unconstitutionally deprived of counsel during a sentencing proceeding based on a state court finding of forfeiture because the petitioner punched his counsel in the head); United States v. Leggett, 162 F.3d 237, 250-51 (3d Cir.1998) (<HOLDING>); Wilkerson v. Burge, No. 03 CIV 3857PKC, 2005
holding that a defendants unprovoked physical battery of his attorney at a hearing qualifies as the sort of extremely serious misconduct that amounts to the forfeiture of the right to counsel holding that a defendant who stipulated his drug amounts prior to sentencing waived his right to appeal on the issue of the drug amounts holding that the forfeiture of the right to counsel unlike the waiver of such right does not require that the defendant intend to relinquish a right but rather may be the result of the defendants extremely serious misconduct or extremely dilatory conduct holding that a defendants unprovoked physical battery of his attorney in the courtroom constituted extremely serious misconduct that amounts to the forfeiture of the right to counsel regardless of whether the defendant intended to relinquish the right recognizing that a criminal defendants right to counsel is the right to the effective assistance of counsel