What is the test for in camera review of a police officer's in-camera report?

"Where, as here, a defendant's undisputed extrajudicial statements are reasonably consistent with the officer's description of the crime, discovery of any complaint of prior fabrication is foreclosed. Why? Because, notwithstanding defense counsel's declaration to the contrary, his client has impliedly acknowledged that the officer has been truthful in his report of the circumstances of the crime. Were we to rule otherwise, imaginative defense counsel could ignore his client's extrajudicial statements and defeat the Pitchess scheme's purpose 'to protect the defendant's right to a fair trial and the officer's interest in privacy [in his personnel records] to the fullest extent possible . . . .' [Citation.]" (People v. Galan (2009) 178 Cal.App.4th 6, 8-9.)

Denial of the charges, in the absence of a plausible alternative version of the facts, does not establish good cause for an in camera review of confidential police personnel records. (People v. Sanderson, supra, 181 Cal.App.4th at p. 1341.) Rather than explain the facts set forth in the police report or the reason for the 911 call, appellant claimed it was all a conspiracy and that the officers "fabricated their observations and falsified their reports to have a basis for the present charges against [appellant] and to secure a conviction." If that was so, the conspiracy involved six arresting officers, a supervising sergeant, a restaurant waitress, two officers in a police airship, two police detectives, and citizens outside the restaurant who pointed appellant out to the police and yelled "Him, that's Him!"

The trial court made a common sense determination that appellant's version of the events was not plausible and failed to establish good cause for an in camera review of the police personnel records. (People v. Thompson, supra, 141 Cal.App.4th

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