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based on the type of criminal case at bar). ] ” Cook v. State, 296 Ga.App. 496, 675 S.E.2d 245 (March 6, 2009). Trial court erred in denying defendant’s motion to discharge counsel and proceed with his appeal pro se; although U.S. Constitution guarantees no right to self- representation on appeal, the Georgia Constitution does. “The trial court found and the State now argues that a criminal defendant does not have the right to self-representation on appeal. The United States Supreme Court held in Martinez v. Court of Appeal, 528 U.S. 152, 120 S.Ct. 684, 145 L.Ed.2d 597 (2000), that the Sixth Amendment of the United States Constitution does not recognize the ‘right to self-representation on direct appeal from a criminal conviction.’ Id. at 163(III). Nevertheless, the Supreme Court also explained that the States were not precluded ‘from recognizing such a right under their own constitutions.’ Id. In Costello v. State, 240 Ga.App. 87, 87-88, 522 S.E.2d 572 (1999), this Court, without discussion, recognized that ‘a defendant has a right to pursue an appeal pro se’ when ‘preceded by an appropriate waiver of the right to appellate counsel.’ (Punctuation omitted.) Id. That decision was based on the Georgia Constitution, [fn: Ga. Const.1983, Art. I, Sec. I, Par. XII (‘No person shall be deprived of the right to prosecute or defend, either in person or by an attorney, that person's own cause in any of the courts of this state.’ ). Compare with U.S. Const. Amend. VI (‘In all criminal prosecutions, the accused shall enjoy the right to a speedy and public trial, by an impartial jury of the State and district wherein the crime shall have been committed, which district shall have been previously ascertained by law, and to be informed of the nature and cause of the accusation; to be confronted with the witnesses against him; to have compulsory process for obtaining witnesses in his favor, and to have the Assistance of Counsel for his defence.’). ] and an earlier Georgia Supreme Court case, Cochran v. State, 253 Ga. 10, 315 S.E.2d 653 (1984) (addressing whether a pro se criminal appellant had validly waived the right to representation by appellate counsel). Thus, while the State is correct that the federal constitution does not recognize the right asserted by Cook, Georgia law does recognize a defendant's right to represent himself on appeal. See Ga. Const.1983, Art. I, Sec. I, Par. XII; Costello, 240 Ga.App. at 87-88, 522 S.E.2d 572.” O. STATEMENT IN PLACE See EVIDENCE – STATEMENT IN PLACE BY ATTORNEY, below P. UNAUTHORIZED PRACTICE OF LAW See OFFENSES – ATTORNEYS – UNAUTHORIZED PRACTICE OF LAW, below Q. WITHDRAWAL See also subheading APPOINTMENT OF COUNSEL – DISCHARGE OF APPOINTED COUNSEL, above Billings v. State, 308 Ga.App. 248, 707 S.E.2d 177 (March 8, 2011). Convictions for child cruelty and related offenses affirmed; no error in denying counsel’s motion to withdraw on the eve of trial, based on defendant’s generalized dissatisfaction with him. “In Bryant v. State, 268 Ga. 616, 617-618(9) (491 S.E.2d 320) (1997), the Georgia Supreme Court concluded that mere ‘“vague complaints” about counsel,’ unsupported by any showing of ‘justifiable dissatisfaction,’ would not support a finding that the trial court abused its discretion in finding that an attempt to discharge counsel was a dilatory tactic. Here, Billings was unable to articulate any support for his claim of threats, beyond stating repeatedly his belief that counsel needed more time.” Odum v. State, 283 Ga.App. 291, 641 S.E.2d 279 (January 19, 2007). The Indigent Defense Act of 2003 (specifically OCGA § 17-12-22) did not divest the trial court of the discretion to consider a public defender’s motion to withdraw due to conflict of interest ; but trial court abused that discretion by denying the motion to withdraw here. OCGA § 17-12-22 requires the Georgia Public Defender Standards Council (“the council”) to establish procedures in the event of conflicts. “Odum argues that a necessary implication of the [Act’s] removal of the trial court’s power to appoint attorneys in indigent cases is that it also transferred to the circuit public defenders’ offices the independent authority to determine when a conflict of interest prevents that office from representing a certain individual. We disagree.” Concerned that this interpretation “would grant defendants and defense counsel significant control over the judicial system” by engaging in dilatory removal maneuvers, the Court of Appeals instead concludes that § 17-12-22 “governs the conduct of public defenders’ offices” without “affecting the trial courts’ authority to apply their procedural rules.” “The fair and efficient operation of our court system, … demands that trial courts remain free to explore, when necessary, ‘the adequacy of the basis of defense counsel’s representations regarding a conflict of interest.’ Holloway v. Arkansas, 435 U.S. 475, 487, 55 L.Ed.2d 426, 98 S.Ct. 1173 (1978).” Trial court abused its discretion in denying the motion here, however. “Uniform Superior Court Rule 4.3 provides that an attorney’s request to withdraw from a case, for any reason, ‘will be granted unless in the judge’s discretion to do so would delay the trial of the action or otherwise interrupt the orderly operation of the court or be manifestly unfair to the client.’ USCR 4.3. Applying this standard, we find that the trial court’s denial of Jennings’ motion to withdraw constituted an abuse of discretion. There was no evidence that referring Odum’s defense to the conflict public defender’s office would delay trial or ‘interrupt the orderly operation of the court.’