Dep't 2000) (concluding that the lower court had “erred in denying defendant's motion on the ground that it was barred by the doctrine of laches” and vacating sentence of defendant, who was convicted in 1954); People v. Kirkland, 781 N.Y.S.2d 627 (Sup.Ct. Kings Co.2003) (conducting an in depth analysis and concluding that "[e]ven if this court is not bound by [the] Reed decision, the court would hold that as a matter of law, laches does not apply to motions to vacate a judgment”); People v. Bell, 179 Misc.2d 410, 686 N.Y.S.2d 259 (Sup.Ct. N.Y.Co.1998) (refusing to dismiss a section 440.10 motion on the basis of laches although convictions occurred over twenty-three years earlier). 170 . U.S. Const, amend. VI; Gideon v. Wainwright, 372 U.S. 335, 344, 83 S.Ct. 792, 9 L.Ed.2d 799 (1963) (<HOLDING>). 171 . See Brecht v. Abrahamson, 507 U.S. 619,
holding that the defendant is entitled to be present at all stages of his trial  and a judges response to a note from the jury is one of those stages holding that the right to counsel applies in all critical stages of state and federal criminal proceedings holding that the confrontation clause did not apply to proceedings before a draft board because such proceedings are not stages in a criminal prosecution holding that sentencing is a critical stage of criminal proceedings and the offer of counsel must be renewed at each critical stage where the defendant appears without counsel holding that defendants have a right to counsel in criminal proceedings