and voluntary”), and United States v. Chaney, 662 F.2d 1148, 1152 (5th Cir. Unit B 1981) ("[A] trial judge must conduct a waiver hearing to make sure that the accused understands the risks of proceeding pro se and that he 'knowingly and intelligently waives the right to counsel’ before permitting the accused to proceed personally.” (quoting Faretta, 422 U.S. at 835, 95 S.Ct. 2525)), with United States v. Keen, 104 F.3d 1111, 1114-45 (9th Cir. 1997) (noting that “preferred procedure” is for court to discuss impact of self-representation in open court, but that there are "limited exception[s]” to this practice "when the record as a whole reveals a knowing and intelligent waiver" (quotation marks and citation omitted)), United States v. Bell, 901 F.2d 574, 578-79 (7th Cir.1990) (<HOLDING>), United States v. Torres, 793 F.2d 436, 438 n.
holding that waiver of counsel during pcr review requires a judicial inquiry into whether defendant knowingly and intelligently waived his right to counsel holding that a defendant can knowingly and intelligently waive his right to counsel only after his sic is aware of the nature of the charges against him the possible penalties and the dangers and disadvantages of selfrepresentation holding that the defendant knowingly and intelligently waived his right to counsel even though the exchange between the magistrate and the defendant was inadequate standing alone to inform the defendant of the dangers and disadvantages of selfrepresentation holding that because the defendant knowingly and intelligently waived his right to separate counsel in light of the courts unambiguous advisement that joint representation could present a very substantial conflict so far as his defense is concerned the defendant was precluded from claiming ineffective assistance of counsel due to the conflict of interest that ultimately developed holding that written waivers referring only in general terms to potential advantages of representation by counsel and potential disadvantages of selfrepresentation did not sufficiently demonstrate awareness of the dangers of selfrepresentation