What is the burden of establishing factual innocence of a defendant under section 851.8 of the California Criminal Code?

A petitioner's burden to establish factual innocence has been described as "'incredibly high'" and as requiring "'no doubt whatsoever.'" (People v. Esmaili (2013) 213 Cal.App.4th 1449, 1459 (Esmaili).) "'Section 851.8 is for the benefit of those defendants who have not committed a crime.'" (Adair, supra, 29 Cal.4th at p. 905, italics added.) A court cannot order the partial sealing and destruction of a factually innocent petitioner's arrest records. Section 851.8 does not provide "for the surgical excision of only certain portions of an arrest record." (Matthews, supra, 7 Cal.App.4th at p. 1063.) "We would defeat the statutory purpose of leaving a factually innocent person with an unblemished record and run afoul of the legislative objective sought to be achieved were we to permit the sealing and destruction of only part of an accused's arrest record." (Ibid.)