What is the test for establishing good cause for a Pitchess hearing?

Further this record contains sufficient facts to support a finding of "good cause of the discovery or disclosure sought, setting forth the materiality thereof to the subject matter involved in the pending litigation." (Evid. Code, 1043, subd. (b)(3).) The threshold for establishing good cause to hold a Pitchess hearing is "relatively low." (City of Santa Cruz v. Municipal Court (1989) 49 Cal.3d 74, 83, 84.)

To show good cause, counsel's supporting declaration "must propose a defense or defenses to the pending charges. The declaration must articulate how the discovery sought may lead to relevant evidence or may itself be admissible direct or impeachment evidence [citations] that would support those proposed defenses. These requirements ensure that only information 'potentially relevant' to the defense need be brought by the custodian of the officer's records to the court for its examination in chambers. [Citations.]" (Warrick v. Superior Court, supra, 35 Cal.4th at p. 1024.) The defense need only describe a "plausible factual foundation" for the claim of "specific police misconduct that is both internally consistent and supports the defense proposed to the charges." (Id. at pp. 1025, 1026.) A scenario sufficient to establish a plausible factual foundation "is one that might or could have occurred." (Id. at p. 1026.)