Illinois Appellate Court
Criminal Court
Right to Counsel
Defendant, who appeared pro se at trial, made valid waiver of counsel after court repeatedly warned him of risks of proceeding without counsel. Court gave Defendant written, rather than oral, admonishments of possible range of sentences, which were substantially in compliance with Rule 401(a). Court properly refused to appoint PD for Defendant at sentencing; Defendant had repeatedly asked to represent himself and then later requested counsel, and Court did not err in refusing his last-minute request to obtain private counsel. (GARCIA and R.E. GORDON, concurring.)