context: P 17 Rasul's threatening behavior and refusal to cooperate with multiple attorneys can be nothing less than part of a " 'plo/ to delay trial."
citation_a.signal: cf.
citation_a.identifier: 53 F.3d 325, 325
citation_a.parenthetical: defendant's threats to sue counsel were factors in forfeiture decision
citation_a.sentence: Cf. McLeod, 53 F.3d at 325 (defendant’s threats to sue counsel were factors in forfeiture decision).
citation_b.signal: see also
citation_b.identifier: 897 A.2d 766, 766
citation_b.parenthetical: noting defendant's conduct fell just short of violence and was intended to force his attorney to withdraw
citation_b.sentence: Carruthers, 35 S.W.3d at 550; see also Bultron, 897 A.2d at 766 (noting defendant’s conduct fell just short of violence and was intended to force his attorney to withdraw). As we have noted, he accused several attorneys of unsatisfactory representation and filed complaints with the state bar.