"[A] defendant who elects to represent himself cannot thereafter complain that the quality of his own defense amounted to a denial of effective assistance of counsel." Faretta v. California, 422 U.S. 806, 834 n.46 (1975); see also Long v. United States, 2011 WL 3876582, at **5-6 (E.D. Tenn. Aug. 31, 2011)(rejecting petitioner's claim that he did not knowingly waive his right to counsel where petitioner had had three attorneys represented to defend him, was told there would not be a fourth and that he would have to proceed pro se if he could not get along with the third attorney, and nonetheless elected to have the third attorney relieved of his responsibility as counsel of record and proceeded pro se). To the extent Fletcher argues that his standby counsel rendered ineffective assistance at trial, the Sixth Circuit Court of Appeals has refused to impose upon standby counsel the same obligations that an attorney would have if the defendant were not proceeding pro se. Holmes v. United States, 281 Fed. Appx. 475, 480-81 (6th Cir. 2008).

To the extent that the performance of standby counsel may have been deficient, Greene merely suffered the consequences of his decision to represent himself. Ross, 703 F.3d at 882; Holmes v. United States, 281 Fed. Appx. 475, 481 (6th Cir. 2008); Wilson, 515 F.3d at 697; Long v. United States, 2011 WL 3876582, * 6 (E.D. Tenn. Aug. 31, 2011). 3. Representation by Counsel During Second Day of Trial