In People v. Jenkins (2000) 22 Cal.4th 900, the defendant insisted he was entitled to a unanimity instruction because the jury could have found him guilty of murder either as the direct perpetrator or as an aider and abettor. (Id. at p. 1024.) The Supreme Court disagreed, noting it was "'settled that as long as each juror is convinced beyond a reasonable doubt that the defendant is guilty of murder as that offense is defined by statute, it need not decide . . . unanimously whether the defendant was guilty as the aider and abettor or as the direct perpetrator." (Id. at pp. 1024-1025.) "Relying upon authority indicating that the unanimity instruction is required if there are multiple acts shown that could have been charged as separate offenses," the defendant in Jenkins argued that "the circumstances in support of his potential accomplice liability--that he was far from the scene when the murder occurred but had aided and abetted in it--were so distinct from the circumstances in support of his potential direct liability--that he had been at the scene and had pulled the trigger--as to constitute two 'discrete criminal events' requiring the unanimity instruction." (Id. at p. 1025.) Still disagreeing, the Supreme Court stated, "In the present case, defendant's conduct as an aider and abettor or as a direct perpetrator could result only in one criminal act and one charge. Under these circumstances, 'jurors need not unanimously agree on whether the defendant is an aider and abettor or a principal even when different evidence and facts support each conclusion.'" (Id. at pp. 1025-1026.) The California Supreme Court acknowledged that a unanimity instruction may be required in particular cases "if there are multiple acts shown to support distinct theories of liability that could have been charged as separate offenses." (Jenkins, supra, 22 Cal.4th at p. 1025.) Where, however, "defendant's conduct as an aider and abettor or as a direct perpetrator could result only in one criminal act and one charge," a unanimity instruction is not required. (Id. at pp. 1025-1026.) In Jenkins, the aiding and abetting theory presumed that the defendant was far from the crime scene at the time of the killing, whereas the direct perpetrator theory had the defendant present and pulling the trigger. (Id. at p. 1025.) Nevertheless, under either theory the defendant's conduct culminated in a single criminal act: the drive-by shooting of a police officer as he approached his car. (Id. at pp. 935, 1025.) The Court explained that "A showing of good cause requires a demonstration that counsel and the defendant have prepared for trial with due diligence. When a continuance is sought to secure the attendance of a witness, the defendant must establish 'he had exercised due diligence to secure the witness's attendance, that the witness's expected testimony was material and not cumulative, that the testimony could be obtained within a reasonable time, and that the facts to which the witness would testify could not otherwise be proven.' The court considers '"not only the benefit which the moving party anticipates but also the likelihood that such benefit will result, the burden on other witnesses, jurors and the court and, above all, whether substantial justice will be accomplished or defeated by a granting of the motion."' " (Jenkins, supra, 22 Cal.4th at p. 1037.) In sum, the defendant contended that "he did not knowingly and intelligently waive his right to counsel, because the court did not warn him of the restrictions that would be imposed on his ability to meet with his investigator and his consultant and to contact and interview witnesses, before it accepted his waiver of the right to counsel." The court stated: "Defendant does not cite any authority establishing that the court must advise a defendant seeking pro se status of each limitation upon his ability to act effectively as counsel that will flow from security concerns and facility limitations, and we have stated, to the contrary, that 'as long as the record as a whole shows that the defendant understood the dangers of self-representation, no particular form of warning is required.'" ( People v. Jenkins, supra, 22 Cal.4th at p. 1042.)