for New Trial Phase, 45 Wm. & Mary L.Rev. 783, 813 (2003). Some federal circuits have held that the right to counsel does not attach to motions for new trial. See United States v. Tajeddini, 945 F.2d 458, 470 (1st Cir.1991); United States v. Lee, 513 F.2d 423, 424 (D.C.Cir.1975); United States v. Birrell, 482 F.2d 890, 892 (2d Cir.1973). We find the reasoning in the former line of authorities persuasive. In this connection, we note that the motion for new trial in each of the cases rejecting a right to counsel was filed and decided after the first appeal of right (or after the defendant forewent a direct appeal) and was characterized by the court as a collateral attack, as to which there is no constitutional right to counsel. See Silva v. People, 156 P.3d 1164, 1167-68 (Colo.2007) (<HOLDING>); 3B Charles Alan Wright, Nancy J. King & Susan
holding that there is no constitutional right to representation by counsel at a parole revocation holding that there is no federal or colorado constitutional right to postconviction counsel but there is a limited statutory right holding that there is no constitutional right to appeal a criminal conviction holding right to testify was federal constitutional right holding that there is no federal constitutional right to a bifurcated criminal trial