☢ test - Í

incidental (and perfectly constitutional) consequences of conviction and incarceration.’ Id. at 355. Clark has not demonstrated that he needed the materials to attack his sentence or challenge the conditions of his confinement, and further has not even demonstrated that the alleged shortcomings of which he complains hindered his efforts to present his defense. Accordingly, we find no error.” 2. Trial court did not err in refusing to subpoena, at defendant’s request, numerous police officers with no direct connection to defendant’s prosecution, where defendant refused to make a showing of relevance. “Clark was offered ample opportunity to subpoena witnesses, but he did not comply with basic rules of criminal procedure, declining assistance, declining to make a proffer of their testimony, and failing to present the State with a list ten days before trial. The trial court committed no error, and Clark was not denied his Sixth Amendment right to represent himself effectively.” Daguilar v. State, 275 Ga.App. 756, 621 S.E.2d 846 (October 6, 2005). Armed robbery and related convictions affirmed. Defendant had no right to have standby counsel conduct parts of the trial while he conducted other parts. “After Daguilar exercised his right to self-representation, the trial court appointed the public defender assigned to the case to advise Daguilar regarding trial strategy, rules of evidence and procedure. The appointed counsel informed the court of his actions as advisor, and the trial court advised Daguilar that he could whisper with and write notes to the public defender during the case. Contrary to Daguilar’s argument, the public defender, as Daguilar’s advisor, could not conduct portions of the trial. The Sixth Amendment does not afford the defendant the hybrid right to simultaneously represent himself and be represented by counsel. Cargill v. State, 255 Ga. 616, 622-623(3) (340 S.E.2d 891) (1986); Vick v. State, 237 Ga.App. 762, 763(2) (516 S.E.2d 815) (1999). While the trial court properly allowed the appointed public defender to assist Daguilar, and even gave them time to practice whispering, it would have been improper for the trial court to allow the attorney, who was acting solely as an advisor, to conduct aspects of the trial after Daguilar exercised his right of self- representation.” Sims v. State, 273 Ga.App. 723, 615 S.E.2d 785 (June 6, 2005). Child cruelty conviction affirmed. “Sims contends that, after having been given pro se status on January 9, 2004, he was not allotted adequate time in a law library to prepare his defense. The record shows that the trial court ordered on February 11, 2004 that Sims be given ‘standard access to the Law Library for the purpose of preparing his case for trial.’ Sims has failed to show that additional time in a law library would have benefited him. Without a showing that Sims was harmed, this contention is without merit. See Florence v. State, 246 Ga.App. 479, 482(9) (539 S.E.2d 901) (2000); accord State v. Heath, 277 Ga. 337 (588 S.E.2d 738) (2003).” Pruitt v. State, 279 Ga. 140, 611 S.E.2d 47 (March 28, 2005). Malice murder and kidnapping convictions affirmed. Trial court did not err in denying defendant’s pre-trial request to allow appointed counsel to withdraw and let him proceed pro se, because his request was not unequivocal. Defendant vacillated between asking to represent himself and saying that he wanted a different lawyer. Winston v. State, 270 Ga.App. 664, 607 S.E.2d 147 (October 29, 2004). Reckless driving and related convictions affirmed. Where defendant made knowing and intelligent waiver of counsel at trial, court was not “obligated to educate her about” rules of evidence. Lamar v. State, 278 Ga. 150, 598 S.E.2d 488 (June 28, 2004). Murder and related convictions reversed; trial court erred by denying defendant’s right to self-represent, following knowing and intelligent waiver of right to counsel. “The standard of mental competency to stand trial is the same as the standard of mental competency to waive the right to counsel. [ Godinez v. Moran, 509 U.S. 389, 398(II)(A) (113 S.Ct. 2680, 125 L.Ed.2d 321) (1993)]. The prohibition against subjecting incompetent persons to trial often is enforced in Georgia pursuant to OCGA § 17-7-130(a), which provides for a special jury trial on the question of competence ‘[w]henever a plea is filed that a defendant in a criminal case is mentally incompetent to stand trial.’ However, even when no such plea is entered, a trial court still bears the constitutional duty to inquire into a defendant’s competency where it ‘appears to be in question at the time of trial.’ Colwell v. State, 273 Ga. 634, 635(2) (544 S.E.2d 120) (2001); see Pate v. Robinson, 383 U.S. 375(II) (86 S.Ct. 836, 15 L.Ed.2d 815) (1966). In Lamar’s case, no plea was made that he was mentally incompetent to stand trial. [Cit.] Nevertheless, the trial court undertook its constitutional duty to inquire into Lamar’s competency. In that regard the trial court, after noting the lack of a request for a competency trial, considered the results of a mental health examination that Lamar had very recently undergone that had shown Lamar to be mentally competent. Based on this information, together with its own observations of Lamar’s pre-trial behavior, the trial court correctly found that competence was not a factor in deciding whether or not to allow Lamar to undertake his own representation. Colwell, supra, 273 Ga. at 637(3)(b).” Court erred in denying defendant’s right to self-representation, however, even where state was seeking the death penalty. “[T]he trial court erroneously failed to follow the procedure in Faretta [ v. California, 422 U.S. 806 (95 S.Ct.