Defendants are entitled to discovery resulting from an internal affairs investigation of the circumstances of their arrests. The defendants here filed motions under Evidence Code sections 1043 and 1045 and Pitchess v. Superior Court (1974) 11 Cal.3d 531, seeking witness statements gathered during an internal affairs investigation. The police department opposed the motion on the grounds that it was overbroad and failed to establish materiality and good cause. The trial court expressed reservations that granting the discovery in this case would create incentive for future defendants to file citizen complaints against arresting officers in order to spark an internal affairs investigation and thus generate discovery. The Court of Appeal reversed the order, acknowledging the trial courts concern but noting that the fact that other defendants might file bad faith claims was not relevant in this case, where the defendants had established that the evidence sought to be discovered was material to the defense.