Task: Text Completion
Input (English): motion at which Pritchett would be represented by counsel or at which the court would determine that Pritchett knowingly, intelligently, and voluntarily waived his right to counsel. Ex parte Pritchett, 117 So.3d at 362. In the instant case, the circuit court immediately appointed new counsel to represent Trimble after Trimble gave his oral notice of appeal. Despite having newly appointed counsel who could file a motion for a new trial attacking his trial counsel’s alleged deficiencies, Trimble elected to file a pro se motion for a new trial. Therefore, unlike the defendant in Pritchett, Trimble had the benefit of newly appointed appellate counsel who represented him and who could file a motion for a new trial on his behalf. See King v. State, 613 So.2d 888 (Ala.Crim.App.1993) 
 Holding statements: (A) holding that a valid waiver of counsel at an early stage of the proceeding does not continue in effect through a subsequent stage (B) holding that posttrial motion for new trial is critical stage requiring counsel or valid waiver (C) holding postindictment lineup is critical stage of trial at which defendant is entitled to presence of counsel (D) holding that the filing of a motion for a new trial is a critical stage of the prosecution and that an indigent defendant is constitutionally entitled to the assistance of counsel at that stage (E) holding that sentencing is a critical stage of criminal proceedings and the offer of counsel must be renewed at each critical stage where the defendant appears without counsel
Output (English): (D)