An appellant is not entitled as of right to audio or video recordings of trial proceedings; access requires demonstration of a particular relevant purpose. Where a ground of appeal alleges judicial bias and the appellant contends that the tone and manner of the judge's speech are relevant, that may constitute a sufficient purpose for release of audio recordings. The standard for assessing whether prison conditions interfere with the right to a fair hearing is not a counsel of perfection but whether the prisoner is prevented from effectively presenting the case.
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