Cohen

MEMORANDUM *

Irwin Schiff and Cynthia Neun appeal various issues arising from their convictions following a jury trial, and Schiff ap *16 peals his sentence. 1 We have jurisdiction pursuant to 28 U.S.C. § 1291 , and we affirm as to all issues addressed here.

First, the district court did not err by failing sua sponte to hold a competency hearing for Schiff. The evidence before the district court did not raise a bona fide doubt as to Schiffs competence to stand trial. See Odle v. Woodford, 238 F.3d 1084, 1087 (9th Cir.2001). Although Schiff submitted reports from two doctors that he suffered from a delusional personality disorder, those reports do not establish any connection between Schiffs delusional views about tax laws and his ability to understand the charges against him or to defend himself at trial. We are satisfied that the record shows Schiff was legally competent.

Second, Schiffs waiver of the right to counsel was knowing, intelligent and unequivocal. See United States v. Arlt, 41 F.3d 516, 519-20 (9th Cir.1994). At the first Faretta hearing, the magistrate judge extensively discussed with Schiff the nature of the charges against him, the possible penalties, and the…