What is the test for a motion for discovery in a civil case?

A showing of good cause or plausible justification for inspection of the material sought is required, although proof of the existence of the item is not required (Hill v. Superior Court, supra, 10 Cal.3d 812, 817, 112 Cal.Rptr. 257, 518 P.2d 1353).

"A showing . . . that the defendant cannot readily obtain the information through his own efforts will ordinarily entitle him to pretrial knowledge of any unprivileged evidence, or information that might lead to the discovery of evidence, If it appears reasonable that such knowledge will assist him in preparing his defense. . . ." (Hill v. Superior Court, 10 Cal.3d 812, 817, 112 Cal.Rptr. 257, 260, 518 P.2d 1353, 1356.)

In their motions for discovery, petitioners assert they intend to rely on a theory

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