The trial court erred in denying discovery of the personnel files of the arresting officers for complaints of fabrication of probable cause and false arrest. The defense attorney’s declaration essentially challenged the officers’ factual account of the detention, search, and manner in which a confession was obtained. The accounts differed about whether the music from defendant’s car was illegally loud, whether the search was done immediately or after discovering that defendant’s license was suspended, and whether Miranda warnings were given before defendant made incriminating statements. The defendant did not have to personally file a declaration; his attorney’s declaration sufficed. Also, the discovery was appropriate when a defendant seeks information to assist in a motion to suppress, as well as the truth of the charges at trial.