What is the test for obtaining discovery of a police officer's personnel records?

To obtain discovery of an officer's personnel records, a defendant must file a motion that includes an affidavit establishing "good cause." (Evid. Code, 1043, subd. (b)(3).) Establishing good cause requires the affiant to "propose a defense or defenses to the pending charges" and "articulate how the discovery sought may lead to relevant evidence or itself may be admissible direct or impeachment evidence [citations] that would support those proposed defenses." (Warrick v. Superior Court, supra, 35 Cal.4th at p. 1024.)