In People v. Carpentier, 446 Mich 19, 28; 521 NW2d 195 (1994), the Supreme Court of Michigan clarified the mandates in Moore regarding the burden a defendant must carry in a collateral attack of a prior conviction, such as in this case. The Court rejected a "presumption of invalidity" where a collateral attack is made on a prior conviction and where the record is silent on whether counsel was validly waived. Carpentier, supra at 36-37, n 10. The Court noted that, "while the presumption of invalidity may enjoy a very obvious and proper place in direct judicial review--simply to insure proper sentencing in the first instance," the presumption of regularity attaches to final judgments that are being collaterally attacked, even when the question is waiver of constitutional rights. Id. at 37. Therefore, where defendant's offers of proof show that he waived his right to counsel for the two prior convictions that he is now collaterally attacking, defendant also carries the initial burden of presenting prima facie evidence that his waivers were invalid.