California, United States of America
The following excerpt is from People v. Vargas, B239488 (Cal. App. 2013):
"Trial courts are granted wide discretion when ruling on motions to discover police officer personnel records. [Citation.]" (People v. Samayoa (1997) 15 Cal.4th 795, 827.) "To obtain relief, . . . a defendant who has established that the trial court erred in denying Pitchess discovery must also demonstrate a reasonable probability of a different outcome had the evidence been disclosed. [Citations.]" (People v. Gaines (2009) 46 Cal.4th 172, 182-183.)
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