What is the test for a defendant to discover a police officer's personnel records?

defendant may discover personnel records is codified in Evidence Code sections 1043 to 1045. Initially, the defendant must submit a motion accompanied by an affidavit or declaration "showing good cause for the discovery or disclosure sought" and "setting forth the materiality thereof to the subject matter involved in the pending litigation." (Evid. Code, 1043, subd. (b)(3).) "To show good cause as required by section 1043, [the] declaration in support of a Pitchess motion must propose a defense or defenses to the pending charges" and "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 ).) The declaration "must also describe a factual scenario supporting the claimed officer misconduct." (Ibid.)