What is the test for obtaining access to personal juror identifying information from a criminal defendant?

Code of Civil Procedure sections 206 and 237 are designed to maximize the safety and privacy of trial jurors after they have served as jurors, while retaining the defendant's ability to contact jurors after trial if he or she shows sufficient need for such information. (See Townsel v. Superior Court (1999) 20 Cal.4th 1084, 1087, 1096; People v. Granish (1996) 41 Cal.App.4th 1117, 1124.) Code of Civil Procedure section 206 authorizes a criminal defendant to petition for access to personal juror identifying information (their names, addresses and phone numbers) when the sealed information is "necessary for the defendant to communicate with jurors for the purpose of developing a motion for new trial or any other lawful purpose." (Code Civ. Proc., 206, subd. (g).) The petition must be supported by a declaration that includes facts sufficient to establish good cause for the

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