The Sixth District holds that attacks to prior OVI convictions based on being uncounseled must be supported with some evidence, even if an affidavit, in the present case; and the Eleventh District holds that probable cause exists when a driver leaves the scene of an accident, gets his vehicle stuck in the mud, has beer cans in his truck, glassy, sleepy eyes, an odor of alcohol, seems confused, and refuses sobriety tests.