What is the test for obtaining access to juror identifying information in a criminal case?

Code of Civil Procedure sections 206 and 237 govern access to juror identifying information in criminal cases. Under these statutes, defendants are entitled to the release of juror identifying information if they "`set[] forth a sufficient showing to support a reasonable belief that jury misconduct occurred, that diligent efforts were made to contact the jurors through other means, and that further investigation is necessary to provide the court with adequate information to rule on a motion for new trial.... [] Absent a satisfactory, preliminary showing of possible juror misconduct, the strong public interests in the integrity of our jury system and a juror's right to privacy outweigh the countervailing public interest served by disclosure of the juror information as a matter of right in each case.' [Citation.]" (Townsel v. Superior Court (1999) 20 Cal.4th 1084, 1093-1094.)