Is a good cause affidavit required before a subpoena can be issued?

affidavit before such a subpoena may be issued. ( Pitchess v. Superior Court (1974) 11 Cal.3d 531, 535, 113 Cal.Rptr. 897, 522 P.2d 305 ( Pitchess ); City of Woodlake v. Tulare County Grand Jury (2011) 197 Cal.App.4th 1293, 1301, 129 Cal.Rptr.3d 241 [no requirement of a "good cause affidavit" "[i]n criminal matters"].) It is important to note, however, that such a criminal subpoena does not command, or even allow, the recipient to provide materials directly to the requesting party. Instead, under subdivision (c) of section 1326, the sought materials must be given to the superior court for its in camera review so that it may "determine whether or not the [requesting party] is entitled to receive the documents." ( Pen. Code, 1326, subd. (c) ; see also People v. Blair (1979) 25 Cal.3d 640, 651, 159 Cal.Rptr. 818, 602 P.2d 738 [such materials cannot legally be given directly to the requesting party].)