California, United States of America
The following excerpt is from People v. Martinez-Berumen, B232636 (Cal. App. 2012):
Furthermore, we have independently reviewed the sealed proceedings and have determined that no information of the nature being sought through the discovery motion was found in the personnel files. The court thoroughly discussed on the record each of the complaints filed against the officer and found no discoverable material to disclose to the defense. There is no basis to disturb the trial court's Pitchess ruling. (People v. Ochoa (2011) 191 Cal.App.4th 664, 674-675.)
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