What is the test for obtaining records of past complaints of excessive use of force by police officers?

There is no case on point. But this court's decision in People v. Zamora (1980) 28 Cal.3d 88, 167 Cal.Rptr. 573, 615 P.2d 1361 (Zamora ) may provide some guidance. There, the defendant was charged with resisting arrest and with battery on a police officer. He sought discovery of past records of unsustained complaints made by citizens alleging excessive use of force by the officers involved. Except for the names of the complainants, all those records had been destroyed about two weeks before the defendant's arrest, depriving him of the opportunity to locate witnesses who might testify about the officers' past use of excessive force.