to counsel,” and district courts must exercise discretion "[d]epending on the circumstances of the individual case”); United States v. Lopez-Osuna, 242 F.3d 1191, 1199 (9th Cir.2001) (rejecting "use [of] a particular script” to assess knowing and intelligent waiver of counsel: "the focus should be on what the defendant understood, rather than on what the court said”); United States v. Kind, 194 F.3d 900, 904 (8th Cir.1999) (noting that district court’s failure "specifically [to] warn[] the defendant of the dangers and disadvantages of self-representation” before allowing him to proceed pro se was not fatal if appellate court could discern from "entire record” that "defendant had the required knowledge from other sources”); United States v. Hughes, 191 F.3d 1317, 1323-24 (10th Cir.1999) (<HOLDING>); United States v. Singleton, 107. F.3d 1091,
holding that in order for a waiver of counsel to be valid the trial court must ensure that the defendants waiver of his right to counsel is done knowingly and intelligently so that the record establishes that the defendants choice is made with eyes open holding that waiver of counsel may be valid absent an inquiry by the court where the surrounding facts and circumstances including the defendants background and conduct demonstrate that he actually understood his right to counsel and the difficulties of pro se representation and knowingly and intelligently waived his right internal quotation marks omitted 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 lower courts misunderstood the requirement for finding a valid waiver of the right to counsel where neither the trial court nor the arizona supreme court undertook to focus on whether edwards understood his right to counsel and intelligently and knowingly relinquished it 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