Does an indigent defendant have a right to obtain a trial transcript to argue a motion for a new trial?

Although an indigent defendant has the right to obtain a trial transcript in connection with an appeal, there is no similar right for the preparation of a new trial motion. As explained in the leading case, "With few exceptions, an accurate trial record, such as a reporter's transcript, is absolutely essential for the proper disposition of a criminal appeal. An appeal is before a different tribunal and, more often than not, is heard many months after the trial is concluded. On the other hand, a motion for a new trial is generally made by the lawyer who participated in the trial, before the judge who presided, and at a time when the testimony adduced is still fresh in everyone's mind. Thus, the need for a full trial transcript to argue a motion for a new trial simply does not exist in the ordinary case." (People v. Lopez (1969) 1 Cal.App.3d 78, 82, fn. omitted.) Nonetheless, "since a motion for a new trial is an integral part of the trial itself, a full reporter's transcript must be furnished to all defendants, rich or poor, whenever necessary for effective representation by counsel at that important stage of the proceeding." (Id. at p. 83.) Each case is decided on its individual circumstances (Ibid.), with the defendant required to make a showing of a "particularized need" for the transcript. (People v. Markley (2006) 138 Cal.App.4th 230, 242.)