What is the test for disclosing evidence of misconduct by a defendant in a civil case?

showing of good cause for the release of the information, the public interest in the integrity of the jury system and the jurors' right to privacy outweighs the defendant's interest in disclosure." (People v. McNally (2015) 236 Cal.App.4th 1419, 1430.)

To make the required prima facie showing of good cause, a petitioning defendant need not introduce admissible evidence establishing juror misconduct actually occurred; rather, it is sufficient to show that talking to jurors is reasonably likely to produce admissible evidence of such misconduct. (People v. Johnson (2013) 222 Cal.App.4th 486, 493.)

Evidence Code section 1150 limits the admissibility of evidence regarding jury deliberations. It states, in part: "Upon an inquiry as to the validity of a verdict, any otherwise admissible evidence may be received as to statements made, or conduct, conditions, or events occurring, either within or without the jury room, of such a character as is likely to have influenced the verdict improperly. No evidence is admissible to show the effect of such statement, conduct, condition, or event upon a juror either in influencing him to assent to or dissent from the verdict or concerning the mental processes by which it was determined." (Id., 1150, subd. (a).) Evidence Code section 1150 " 'distinguishes "between proof of overt acts, objectively ascertainable, and proof of the subjective reasoning processes of the individual juror, which can be neither corroborated nor disproved . . . ." ' " (People v. Danks (2004) 32 Cal.4th 269, 302.)