What is sufficient for a Pitchess motion for abuse of discretion?

To be sufficient, a Pitchess motion must include, among other thing, an affidavit showing good cause for the discovery of a peace officer's personnel records "first by demonstrating the materiality of the information to the pending litigation, and second by 'stating upon reasonable belief' that the police agency has the records or information at issue." (Warrick v. Superior Court (2005) 35 Cal.4th 1011, 1019 (Warrick).) "[D]efense counsel's declaration . . . must propose a defense or defenses to the pending charges" and "articulate how the discovery sought may lead to relevant evidence or may itself be admissible direct or impeachment evidence [citations] that would support those proposed defenses." (Id. at p. 1024.) It must also "describe a factual scenario supporting the claimed officer misconduct." (Ibid.) In some circumstances, the factual scenario "may consist of a denial of the facts asserted in the police report." (Id. at pp. 1024-1025.) Such a denial may establish a reasonable inference that the reporting officer may not have been truthful. (Id. at p. 1022.) But this is not true for all cases. "What the defendant must present is a specific factual scenario of officer misconduct that

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is plausible when read in light of the pertinent documents." (Id. at p. 1025.) We review the denial of a Pitchess motion for abuse of discretion. (People v. Mooc (2001) 26 Cal.4th 1216, 1228.)