Can a defendant who claims self-defense to a charge of battery upon a police officer, who is also charged with battery upon the officer, obtain materials from the police department concerning the propensity for violence against the officer?

The Pitchess court held that a defendant who claims self-defense to a charge of battery upon a police officer is entitled to discover materials in possession of the police department concerning any propensity of the officer to commit acts of violence. The defendant in Pitchess was found to have demonstrated good cause for discovery where the information sought was 1) relevant to his defense of self-defense (see Evid. Code, 1103 regarding admissibility of prior acts), 2) necessary in that the defendant could not readily obtain the information through his own efforts, and 3) described with adequate specificity to preclude the possibility that the defendant was engaging in a "fishing expedition." (Pitchess v. Superior Court, supra, at pp. 537-538, 113 Cal.Rptr. 897, 522 P.2d 305.)