Is there any evidence that a police officer fabricates reports?

California, United States of America

The following excerpt is from People v. Murphy, C078961 (Cal. App. 2018):

Defendant insisted that certain call logs showed the officer lied about being sent to that location, and complained that counsel had not tried to find any impeaching evidence about the officer's alleged history of fabricating reports. Counsel replied that he knew of no basis to file a Pitchess motion (see Pitchess v. Superior Court (1974) 11 Cal.3d 531 (Pitchess)) to try to see the personnel records of the officers; that is, he did not believe he could make the threshold showing to bring such a motion.

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