Does a defendant have to provide a "specific factual scenario" to support his claim that his confession was coerced?

Memro is clearly distinguishable from the instant case. There, by asserting that his confession was coerced by promises of leniency and threats of violence, the defendant provided a "specific factual scenario" establishing a "plausible factual foundation" for the allegations of police misconduct and which thereby enabled the trial court to determine the materiality of "the discovery or disclosure sought" to "the subject matter involved in the pending litigation." (See City of Santa Cruz v. Municipal Court, supra, 49 Cal.3d at pp. 85-86, 260 Cal.Rptr. 520, 776 P.2d 222; Evid.Code, 1043, subd. (b)(3).)

Here, defendant asserted that "knowing and voluntary consent to enter was not in fact obtained," without explaining in what respect the search was illegal. Similarly, defendant only asserted that the police reports contained "material misrepresentations" and that the police had "mishandled" evidence, without explaining what the misrepresentations were, what items of evidence were mishandled, or how the evidence was mishandled. He therefore failed to provide a "specific factual scenario" establishing a "plausible factual foundation" for the allegations. (See City of Santa Cruz v. Municipal Court, supra, 49 Cal.3d at pp. 85-86, 260 Cal.Rptr. 520, 776 P.2d 222.) ⁶ Without some notice of the specifics of the allegedly improper police conduct, the trial court could not determine whether "the discovery or disclosure sought" was material to "the subject matter involved in the pending litigation." (Evid.Code, 1043, subd. (b)(3).)