the contents of Roberts’s phone call. Cf. Escobedo v. Illinois, 378 U.S. 478, 84 S.Ct. 1758, 12 L.Ed.2d 977 (1964). Requiring police to honor a lawyer’s unsolicited request to be present during interrogation would in effect create an “undifferentiated right to the presence of an attorney that is triggered automatically by the initiation of the interrogation itself.” Burbine, 475 U.S. at 434 n. 4, 106 S.Ct. at 1147 n. 4. Miranda expressly rejected the idea that “each police station must have a ‘station house lawyer’ present at all times to advise prisoners.” Miranda, 384 U.S. at 474, 86 S.Ct. at 1628. In sum, the necessity of a clear request for counsel in the Fifth Amendment context has remained paramount in application of Miranda, see, e.g., Davis, 512 U.S. at 461, 114 S.Ct. at 2356 (<HOLDING>); Mosley, 423 U.S. at 104 n. 10, 96 S.Ct. at
holding that fifth amendment protection against selfincrimination requires police to notify suspect of right to counsel and to cut off interrogation once suspect invokes the right absent counsel further interrogation may not occur unless suspect initiates subsequent conversation if police initiate subsequent interrogation there can be no valid waiver of counsel even though police advise suspect of his or her constitutional rights and suspect acquiesces in the interrogation holding that the state courts conclusion that a suspect did not unambiguously request counsel was not unreasonable when during a postmiranda interview the suspect stated i think i would like to talk to a lawyer after which the police stopped questioning him left the room and did not resume questioning until the suspect explicitly said he did not want a lawyer and wanted to continue talking holding that unless suspect clearly requests counsel police do not have to halt questioning holding to constitute a seizure a suspect must do more than halt temporarily he must submit to police authority holding suspect must unambiguously request counsel before applying rule established in edwards that police questioning must cease once suspect requests counsel during interview