In People v. Dougherty (1983) 143 Cal. App. 3d 245, the petition was filed 66 days late, 28 days longer than the delay in the present case. Based on counsel's allegations, the Dougherty court concluded "that the delay had the prejudicial effect of depriving counsel of an adequate time to prepare. " ( Id., at p. 248, ) The allegations were different from those of appellant's counsel. Counsel in Dougherty alleged that (1) "there had been insufficient time to secure the appointment of medical experts"; (2) he had not had time to subpoena the defendant's psychiatric file and was therefore unable to effectively cross-examine a psychologist; and (3) "he was incapable of effectively cross-examining the psychologist without professional assistance." ( Id., at p. 248.)