What is the test for obtaining discovery of a police officer's personnel records and complaints against such officers?

To obtain Pitchess discovery of a police officer's personnel records and complaints against such officers, a defendant or petitioner must file a motion describing the type of records sought and showing, inter alia, the materiality of the information to the subject of the pending action and good cause for disclosure. (Evid. Code, 1043, 1045.) "To show good cause as required by section 1043, defense counsel's declaration in support of a Pitchess motion must propose a defense or defenses to the pending charges. The declaration must articulate how the discovery sought may lead to relevant evidence or may itself be admissible direct or impeachment evidence [citation] that would support those proposed defenses." (Warrick v. Superior Court (2005) 35 Cal.4th 1011, 1024 (Warrick).) "Counsel's affidavit must also describe a factual scenario supporting the claimed officer misconduct." (Ibid.) "The court then determines whether defendant's averments, '[v]iewed in conjunction with the police reports' and any other documents, suffice to 'establish a plausible factual foundation' for the alleged officer misconduct and to 'articulate a valid theory as to how the information sought might be admissible' at trial. [Citation.] Although a Pitchess motion is obviously strengthened by a witness account

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