In People v. Gissendanner, 48 NY2d 543 (1979), the Court of Appeals, construing the then-recently enacted provisions of Civil Rights Law 50-a2, announced the balance to be struck where a criminal defendant's constitutional rights to compulsory process and confrontation conflict with the cloak of confidentiality surrounding police personnel files. The Court explained that subpoenas for such records could not be used for discovery purposes to ascertain the existence of evidence, but rather require the putting forth of a good faith factual predicate making it reasonably likely that: "the record actually contains information that carries a potential for establishing the unreliability of either the . . . charge or of a witness upon whose testimony it depends. (People v. Gissendanner, 48 NY2d at 550). Specifically, the defendant must demonstrate "a likelihood that the police witness' prior criminal or disciplinary record may provide a motive to falsify," or that the witness' prior acts of misconduct believed to be within such records "bear peculiar relevance to the circumstances of defendant's case." (Id., at 549). The New York high court drew a distinction between personnel information that is directly relevant to the defendant's guilt or innocence and, on the other hand, personnel information that merely provides grounds for impeaching a police witness on collateral issues, or on matters of the witness's general credibility: Disclosure must be granted when otherwise confidential data is relevant and material to the determination of the defendant's guilt or innocence, as, for example, when a request for access is directed toward revealing specific "biases, prejudices, or ulterior motives of the witness as they may relate directly to issues or personalities in the case at hand," or when the request involves other information which, if known to the trier of fact, could very well affect the outcome of the trial ... . But disclosure need not be granted when requests to examine personnel records are motivated by nothing more than impeachment of witnesses' general credibility or when ... the defendant has failed to demonstrate any theory of relevancy and materiality, but, instead, merely desires the opportunity for an unrestrained foray into confidential records in the hope that the unearthing of some unspecified information would enable him to impeach the witness. (Gissendanner,