What is the test for a motion to discover law-enforcement personnel records relevant to a defendant's defense?

California, United States of America


The following excerpt is from People v. E.G. (In re E.G.), A152332 (Cal. App. 2019):

Under well-established Pitchess procedure, a criminal defendant may bring a motion to discover law-enforcement personnel records relevant to a defendant's defense. (People v. Mooc (2001) 26 Cal.4th 1216, 1225.) If the court finds the defendant has shown good cause for the discovery, the court must conduct an in camera hearing to determine if any relevant records must be produced. (Id. at p. 1226.) At the hearing, the custodian of records must bring to court all documents " 'potentially relevant' " to the defendant's motion. (Id. at pp. 1228-1229.) The custodian of records is not required to

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