What is the test for showing good cause for disclosure in a civil case?

subject of the pending action and good cause for disclosure. (Evid. Code, 1043, 1045.) "To show good cause as required by section 1043, defense counsel's declaration in support of a Pitchess motion 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." (Warrick v. Superior Court (2005) 35 Cal.4th 1011, 1024 (Warrick).) "Counsel's affidavit must also describe a factual scenario supporting the claimed officer misconduct." (Ibid.) "The court then determines whether defendant's averments, '[v]iewed in conjunction with the police reports' and any other documents, suffice to 'establish a plausible factual foundation' for the alleged officer misconduct and to 'articulate a valid theory as to how the information sought might be admissible' at trial. [Citation.] . . . What the defendant must present is a specific factual scenario of officer misconduct that is plausible when read in light of the pertinent documents." (Id. at p. 1025.) "[A] plausible scenario of officer misconduct 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." (Id. at p. 1026.)

If the trial court grants the motion, it should only order disclosure of complaints or incidents directly relevant to the specific factual scenario asserted by the defendant. (Warrick, supra, 35 Cal.4th at pp. 1022, 1027 [defendant who asserted police falsely accused him of discarding controlled substance entitled to discover complaints of making false arrests, planting evidence, committing perjury, and falsifying police reports or probable cause, but not reports of using excessive force or exhibiting racial, gender or sexual orientation bias]; People v. Jackson (1996) 13 Cal.4th 1164, 1220 [defendant who claimed officers coerced his confession entitled to discover only complaints alleging coercive interrogation techniques, not all excessive force complaints].)

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