In People v. Little, 259 A.D.2d 1031 (1999), defendant Little was represented by counsel in 1988 in connection with plea negotiations regarding robbery and homicide charges. The defendant did not accept the plea offer and pleaded guilty to the robbery charges alone. Nine years later, he made an inculpatory statement to the police regarding the homicide. While incarcerated, the defendant made two pro se motions and was represented by another attorney regarding the robbery conviction. In addition (unlike the instant case), the Court found that the police were unaware that defendant had counsel when the investigation began in 1988.