Wiggins v. State, 298 Ga. 366, 782 S.E.2d 31, 35 (2016). 70 . Stringer v. State, 241 S.W.3d 52, 56 (Tex. Crim. App. 2007) (quoting Brookhart v. Janis, 384 U.S. 1, 4, 86 S.Ct. 1245, 1247, 16 L.Ed.2d 314 (1966)). One court focused on two key words—"known right”—in the phrase "known right or privilege.” Johnson v. Zerbst, 304 U.S. 458, 464-65, 58 S.Ct. 1019, 1023, 82 L.Ed. 1461 (1938). 71 . Faretta, 422 U.S. at 835, 95 S.Ct. at 2541. 72 . Davison v. State, 405 S.W.3d 682, 686 (Tex. Crim. App. 2013). 73 . Brown, 665 F.2d at 611 (citing Chapman, 553 F.2d at 893 & n,12), 74 . Id.) Winton, 837 S.W.2d at 135; Robinson v. State, 387 S.W.3d 815, 820-21 (Tex. App-Eastland 2012, no pet.); see also Faretta, 422 U.S. at 835-36, 95 S.Ct, at 2541; Wilson v. Walker, 204 F.3d 33, 38 (2d Cir.) (<HOLDING>), cert. denied, 531 U.S. 892, 121 S.Ct. 218,
holding that petitioner abandoned initial request when he subsequently had two different lawyers appointed and did not assert right again after question of selfrepresentation had been left open for further discussion holding a selfrepresentation request untimely where made after voir dire had begun but before the jury had been empaneled holding that trial court abused its discretion in denying petitioners request for counsel in evidentiary hearing where petitioner had requested counsel and had indicated in his motion that all documents had been prepared by prison law clerk he had only ninthgrade education he had no training in the law and he lacked the skills necessary to participate in hearing holding that after two years of litigation the employer had waived any right it had to compel arbitration holding that right of selfrepresentation did not attach because defendant had made no indication of his desire to proceed without counsel