What is the test for materiality in a civil case?

"[The] touchstone of materiality is a 'reasonable probability' of a different result." (Kyles v. Whitley, supra, 514 U.S. at p. 434.) That is, whether in the absence of the withheld evidence, he received a fair trial, understood as a trial resulting in a verdict worthy of confidence. (Ibid.)

"'Materiality includes consideration of the effect of the nondisclosure on defense investigations and trial strategies.'" (People v. Cordova, supra, 62 Cal.4th at pp. 123-124.) In assessing materiality, "'an incomplete response to a specific [Brady] request not only deprives the defense of certain evidence, but also has the effect of representing to the defense that the evidence does not exist. In reliance on this misleading representation, the defense might abandon lines of independent investigation, defenses, or trial strategies

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