Can a defendant subpoena the personnel records of a police officer?

Prior to the enactment of section 50-a of the Civil Rights Law, the cases were in conflict as to whether and under what circumstances defendants could subpoena personnel records of police officers. In People v. Sumpter, 75 Misc.2d 55, 347 N.Y.S.2d 670, the court noted (1) the trend toward mutual disclosure, (2) that the prosecution usually has available to it a substantial amount of information which could be used to impeach a defendant's credibility and (3) that cases often turn upon the credibility of police officers. The duty of furnishing exculpatory evidence to the defense was held to extend to material going to the question of the credibility of prosecution witnesses. However, the court also noted the immense problems which unlimited disclosure could bring (p. 60, 347 N.Y.S.2d p. 677):