The prosecution does not have a constitutional obligation to disclose complaints about police officer misconduct where the only evidence of such misconduct is defense testimony in an unrelated criminal trial. The court concluded such a proposed rule was logistically impossible, and would require the People to catalogue the testimony of every witness called by the defense in every criminal case in the county. Moreover, a defense attack on the integrity of a police officer is a common feature of criminal trials, but such attacks are not as trustworthy as a sustained citizen complaint in the officer’s personnel file.