Defendant's constitutional right to counsel was violated when the trial court denied his request for substitution of counsel without making any inquiry or giving defendant an opportunity to state the basis of his complaint, and instead, diverted defendant from his application by turning the discussion to the question of whether he wanted to proceed pro se. While applications which appear to be delaying tactics may be reviewed skeptically, and may well be justifiably denied, especially on the eve of trial ( People v Medina, 44 NY2d 199, 207-208), the defendant must at least be given an opportunity to state the basis for his application ( see People v Sides, 75 NY2d 822, 824; People v Brown, 305 AD2d 422).