What is the meaning of a declaration of denial of accusations in the police report?

Here, defense counsel's declaration was neither a "simple denial of accusations in the police report" nor "an alternative version of what might have occurred." (Garcia v. Superior Court, supra, 42 Cal.4th at p. 72; Warrick, supra, 35 Cal.4th at p. 1026.) The declaration did not propose any defense to the charged offenses nor articulate how the requested discovery would support any such defense. Instead, so far as Officer Tennis was concerned, the declaration simply averred: "Without consent or a warrant, Officer

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