discussed Cited "see" Simpson v. Owens (2×) See People v. Barnett, 17 Cal.4th 1044 , 74 Cal.Rptr.2d 121 , 954 P.2d 384 (contrasting a case in which a capital defendant presented no legal argument why he should be released to assist an investigator to a juvenile case in which race was a barrier to locating and persuading potential witnesses to testify for the defendant), cert. denied, 525 U.S. 1044 , 119 S.Ct. 598 , 142 L.Ed.2d 539 (1998); State v. Tibbetts, 92 Ohio St.3d 146 , 749 N.E.2d 226, 241-42 (2001)(finding that capital defendant must make particularized arguments describing why he was or would be unable to adequately assist in p…