When three of defendant’s four appointed attorneys withdrew following threats by defendant, trial court did not err by declining to appoint a fifth attorney.

Would it have been better had the court had advise defendant of the risks of self-representation? Maybe. But the Court of Appeals found the trial judge’s warning that defendant’s misconduct toward his attorneys would have unspecified “consequences” was “adequate”

State v. Garrett 299 Or App 744 ( 2019)