P.

DISCUSSION

I. Contentions

Defendant contends that the Marsden motion should have been granted. He claims his appointed counsel argued against his interest and undermined his credibility when she stated defendant was “playing games.” Respondent contends that the trial court properly denied defendant's Marsden motion. Respondent argues that the context of the interaction between the appellant and defense counsel, a Marsden hearing, was an appropriate venue for defense counsel to address defendant‟s complaints.

II. Standard of Review

We review the denial of a Marsden motion for abuse of discretion. (People v. Memro (1995) 11 Cal.4th 786, 857.) “Denial „is not an abuse of discretion unless the defendant has shown that a failure to replace the appointed attorney would “substantially impair” the defendant‟s right to assistance of counsel. [Citations.]‟ ” (People v. Barnett (1998) 17 Cal.4th 1044, 1085.)

III. Defense Counsel Provided Relevant Information to the Court During the

Marsden Hearing It is well established that Marsden hearings provide a forum for defendants to present complaints about the effectiveness of their counsel and seek removal. (Marsden, supra, 2…