Does a Pitchess motion need to provide a motive for the alleged officer misconduct?

A Pitchess motion need not, however, provide a motive for the alleged officer misconduct. We do not require the prosecutor to prove motive at trial in order to obtain a conviction. (CALJIC No. 2.51.) It would be anomalous to require a criminal defendant to do so in order to obtain discovery. Moreover, because most defendants will only be able to postulate an officer's motive for misconduct, to require every defendant to demonstrate a motive would require most of them "to allege with particularity the very information" they seek to discover. (People v. Memro, supra, 38 Cal.3d at p. 684, 214 Cal.Rptr. 832, 700 P.2d 446.) Imposing a motive requirement would be contrary to the principles of discovery and would, in most instances, require defense counsel to engage in rank speculation.