Ruiz-Ochoa v. Holder
February 28, 2010
**Right to counsel during bond determination**
Ruiz-Ochoa was not denied his right to counsel because he knowingly and voluntarily waived his right to counsel when he affirmatively asked the IJ to proceed with his bond determination without counsel after the IJ had offered to continue his hearing for a third time in order to secure counsel.
http://www.ca9.uscourts.gov/datastore/memoranda/2010/02/26/07-74787.pdf
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