In Voit v. Superior Court (2011) 201 Cal.App.4th 1285, the superior court clerk refused to file the motion of a pro se incarcerated defendant for appointment of counsel because it did not cite precedent in support; the Court of Appeal issued a peremptory writ finding that the clerk's office had exceeded the limits of its ministerial duties, resulting in the deprivation of the right of access to the courts. (Id. at pp. 1287-1288.)