Gottschalk v. State
In Gottschalk v. State, 602 P.2d 448, 450-51 (Alaska 1979) the defendant waived his right to counsel and trial began with Gottschalk representing himself. However, after the trial began, Gottschalk requested a continuance to consult with an attorney he was about to hire.
The trial court denied his request. The Alaska Supreme Court affirmed the trial court's decision, noting that it was the defendant's neglect in failing to hire an attorney earlier that had led to his request for a continuance.