When will a court refuse to release a grand jury minutes to defense counsel?

When considering release of grand jury minutes to defense counsel, a court must engage in a two-pronged analysis: (1) determination of whether there has been a showing of a compelling and particularized need, and (2) the weighing of various factors to assess whether disclosure is appropriate under the circumstances presented. See People v. Robinson, 98 NY2d 755 [2002]. A court will not release grand jury minutes if a defendant cannot meet the threshold burden of demonstrating there is a compelling and particularized need for release of said minutes to defense counsel.