California, United States of America
The following excerpt is from Craig v. Municipal Court, 100 Cal.App.3d 69, 161 Cal.Rptr. 19 (Cal. App. 1979):
The currently popular practice of defendants seeking discovery of information concerning the past conduct of the arresting officers had its genesis in Pitchess v. Superior Court, supra. Thus, it is appropriate to commence our discussion with a brief analysis of that case.
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