Can a defendant request post-conviction discovery under section 1054.9 of the California Penal Code?

Trial courts have little discretion to deny a request for post-conviction discovery under Penal Code section 1054.9. (See Catlin v. Superior Court (2011) 51 Cal.4th 300.) As the statute does not provide for representation by counsel (cf. Pen. Code, 1405, which does provide for the appointment of counsel when a defendant seeks DNA testing), courts should not impose unnecessary procedural bars. While it is not entirely clear how petitioner presented his request to the trial court, we are persuaded that he is entitled to a point-by-point determination on the merits of his requests.