What is the test for establishing a plausible factual foundation in a civil case?

state a reasonable belief that the records contain the type of information sought. [Citation.]" (People v. Thompson (2006) 141 Cal.App.4th 1312, 1316.) "[T]he defendant must ' "establish a plausible factual foundation" ' for its defense. [Citation.] To do so, the defendant 'must present ... a specific factual scenario of officer misconduct that is plausible when read in light of the pertinent documents.' [Citation.] A scenario sufficient to establish a plausible factual foundation 'is one that might or could have occurred. Such a scenario is plausible because it presents an assertion of specific police misconduct that is both internally consistent and supports the defense proposed to the charges.' [Citation.] [] Depending on the circumstances of the case, the denial of facts described in the police report may establish a plausible factual foundation. [Citation.] A factual scenario does not have to be reasonably probable or credible." (Id. at pp. 1316-1317, italics in original.)