What is the current state of the law on the disclosure of evidence in a civil case?

In Brady v. Maryland (1963) 373 U.S. 83, the court held that "the suppression by the prosecution of evidence favorable to an accused upon request violates due process where the evidence is material either to guilt or to punishment, irrespective of the good faith or bad faith of the prosecution." (Id. at p. 87.) "The high court has since held that the duty to disclose such evidence exists even though there has been no request by the

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accused [citation], that the duty encompasses impeachment evidence as well as exculpatory evidence [citation], and that the duty extends even to evidence known only to police investigators and not to the prosecutor [citation]." (People v. Salazar (2005) 35 Cal.4th 1031, 1042; People v. Letner and Tobin (2010) 50 Cal.4th 99, 175.)