When "a defendant voices a seemingly substantial complaint about counsel, the court should inquire into the reasons for dissatisfaction." United States v. Simeonov, 252 F.3d 238, 241 (2d Cir. 2001). If the court "refuses to inquire into a seemingly substantial complaint about counsel... the defendant may then properly claim denial of his Sixth Amendment right." United States v. Calabro, 467 F.2d 973, 986 (2d Cir. 1972). However, if the reasons underlying the defendant's grievance are made known to the court, the court may rule on the defendant's request for new counsel without further inquiry. Id.; see also United States v. Bliss, 430 F.3d 640, 65152 (2d Cir. 2005) (holding that the district court did not abuse its discretion by ruling without further inquiry where the court had been apprised of the reasons for the defendant's request for new counsel). Moreover, a defendant suffers no harm from the court's denial of his or her request without further inquiry into the matter "if the reasons proffered are insubstantial and the defendant receives competent representation from [current] counsel." United States v. John Doe No. 1, 272 F.3d 116, 123 (2d Cir. 2001).

Here, Defendant complains, without elaboration, that her current counsel "did not handle [her] trial properly," or "guide [her] through the process correctly." (See ECF No. 249.) In addition, Defendant complains that "there were several misunderstandings," due to the language barrier between her and her current counsel, and therefore she "would prefer" a Spanish-speaking attorney. (Id.) Because Defendant's bases in support of her request for new counsel are insubstantial, and because the Court has no basis to conclude that she did not receive competent representation at trial, Defendant's motion to appoint new counsel 249 is DENIED. Ordered by Judge LaShann DeArcy Hall on 12/7/2023. (CG) (Entered: 12/08/2023)

When "a defendant voices a seemingly substantial complaint about counsel, the court should inquire into the reasons for dissatisfaction." United States v. Simeonov, 252 F.3d 238, 241 (2d Cir. 2001). However, if the reasons underlying the defendant's grievance are made known to the court, the court may rule on the defendant's request for new counsel without further inquiry. See United States v. Bliss, 430 F.3d 640, 65152 (2d Cir. 2005) (holding that the district court did not abuse its discretion by ruling without further inquiry where the court had been apprised of the reasons for the defendant's request for new counsel).

Here, Defendant and his counsel have each represented that the attorney-client relationship is "significantly damaged" and "beyond repair." (See ECF Nos. 246 and 248.) The Court is satisfied, based upon Defendant and his counsel's submissions, that there is good cause for the appointment of new counsel without further inquiry. Defendant and his counsel's motions to appoint new counsel 246 and 248 are GRANTED. Ordered by Judge LaShann DeArcy Hall on 12/7/2023. (CG) (Entered: 12/07/2023)