In what circumstances will a judge grant defense access to jury records and reports from the prosecution?

In People v. Murtishaw (1981) 29 Cal.3d 733, 765-767, 175 Cal.Rptr. 738, 631 P.2d 446, we announced a rule giving trial judges "discretionary authority to permit defense access to jury records and reports of investigations available to the prosecution." (Id. at p. 767, 175 Cal.Rptr. 738, 631 P.2d 446.) The rule was founded on our power to supervise the administration of criminal procedure and arose from a concern that prosecutors would have more information about prospective jurors than defense lawyers because of their superior ability to finance investigations of the venire. As we stated: "Such a pattern of inequality reflects on the fairness of the criminal process." (Id. at pp. 766-767, 175 Cal.Rptr. 738, 631 P.2d 446.)