What is the test for disclosing records of internal affairs in a civil case?

A trial court has broad discretion in determining what to disclose pursuant to a Pitchess motion, and we will reverse the court's determination only on a showing of abuse of discretion. (Haggerty v. Superior Court (2004) 117 Cal.App.4th 1079, 1086.) According to Evidence Code section 1045, subdivision (a), parties have a "right of access to records of complaints, or investigations of complaints . . . concerning an event or transaction in which the peace officer or custodial officer" at issue participated, "provided that information is relevant to the subject matter involved in the pending litigation." While plaintiff argues the internal affairs investigators' conclusions and findings were relevant, she cites no authority to support this assertion. In fact, the case she cites held the law enforcement department in an excessive force lawsuit did not have

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