What is the test for disclosure under section 206 of the California Code of Civil Procedure?

California, United States of America


The following excerpt is from People v. Duran, 50 Cal.App.4th 103, 57 Cal.Rptr.2d 635 (Cal. App. 1996):

"[T]he last sentence of section of section 206 of the Code of Civil Procedure merely regulates to whom, not whether, disclosure shall be made. In addition, former subdivision (f) of section 206 ... limits the disclosure 'for the purpose of developing issues on appeal or any other lawful purpose.' Although this language is broad, it does indicate a legislative intent to require the defendant to show good cause for disclosure and not engage in merely a fishing expedition." (People v. Wilson, supra, 43 Cal.App.4th at p. 852, 50 Cal.Rptr.2d 883.)

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