In Hoversten v. Superior Court (1999) 74 Cal.App.4th 636, the Second District reviewed a case also involving an incarcerated indigent father seeking visitation rights. The court recognized that reasonable visitation is a substantial right, even for a prisoner, and that access to the courts is also significant. Hoversten held it was incumbent upon the court to "assure . . . some kind of access," giving due consideration to the nature of the action, the prisoner's role and the need for his presence, and the feasibility of transferring him to court. The court proposed various remedies, including deferring the action, appointing counsel, transferring the prisoner to court, conducting hearings by telephone or closed circuit television, using declarations, or using a mediator to make recommendations to the court. (Hoversten v. Superior Court, supra, 74 Cal.App.4th at pages 643-644.)