What is the test for a criminal defendant to compel discovery of police personnel records?

These principles were applied in Pitchess to permit the discovery of police personnel records. As we explained, a criminal defendant's right to discovery is based on the "fundamental proposition that [an accused] is entitled to a fair trial and an intelligent defense in light of all relevant and reasonably accessible information." (Pitchess v. Superior Court, supra, 11 Cal.3d at p. 535, 113 Cal.Rptr. 897, 522 P.2d 305, italics added.) Pitchess made it clear that "an accused ... may compel discovery by demonstrating that the requested information will facilitate the ascertainment of the facts and a fair trial." (11 Cal.3d at p. 536, 113 Cal.Rptr. 897, 522 P.2d 305.) In contrast [49 Cal.3d 85] to the detailed showing required by some civil discovery statutes (Code Civ.Proc., 1985, 2036), the requisite showing in a criminal matter "may be satisfied by general allegations which establish some cause for discovery" other than a mere desire for all information in the possession of the prosecution. (11 Cal.3d at pp. 536-537, 113 Cal.Rptr. 897, 522 P.2d 305.) The information sought must, however, be "requested with adequate specificity to preclude the possibility that defendant is engaging in a 'fishing expedition.' " (Id. at p. 538, 113 Cal.Rptr. 897, 522 P.2d 305.)