In People v. Thompson (2006) 141 Cal.App.4th 1312, an undercover police officer purchased narcotics from the defendant. The buy money had been photocopied for later identification. (Id. at p. 1315.) Six other officers witnessed the transaction, and two others monitored the wired dialogue between the buyer-officer and defendant. After the transaction, another officer found money on the defendant's person, and yet another (the 11th involved in the case) confirmed that the money found on defendant was the buy money. (Id. at p. 1317.) To justify Pitchess discovery, defense counsel submitted a declaration in which he stated that defendant did not possess the buy money and did not engage in a narcotics transaction. He claimed that defendant was arrested simply because he was in an area where arrests were occurring, and that the police attributed the sale to him because they learned he had a criminal record. (Thompson, supra, 141 Cal.App.4th at p. 1317.) In finding the defense showing inadequate to justify discovery of personnel records of the 11 officers involved, the court reasoned the defendant, rather than presenting a plausible factual scenario of officer misconduct, presented an entirely implausible claim that 11 officers conspired to frame him simply because he was standing without explanation at a particular location. (Thompson, supra, 141 Cal.App.4th at p. 1318.) The court reasoned: "We are aware that Thompson the defendant need not present a factual scenario that is reasonably likely to have occurred or is persuasive or even credible. Further, we cannot conclude that Thompson's scenario is totally beyond the realm of possibility. Thompson's denials 'might or could have occurred' in the sense that virtually anything is possible. The decision in Warrick v. Superior Court (2005) 35 Cal.4th 1011 did not redefine the word 'plausible' as synonymous with 'possible,' and does not require an in camera review based on a showing that is merely imaginable or conceivable and, therefore, not patently impossible. Warrick permits courts to apply common sense in determining what is plausible, and to make determinations based on a reasonable and realistic assessment of the facts and allegations." (Id. at pp. 1318-1319.) In People v. Thompson (2006) 141 Cal.App.4th 1312, the police claimed that Thompson gave an undercover officer cocaine base in exchange for two prerecorded $ 5 bills. The officer was "wired" during the transaction, and several other officers who were part of the "buy team" operation watched and listened to the transaction. Thompson was arrested by the other officers after the exchange was completed, and the prerecorded bills were found on his person. He was thereafter charged with the sale of cocaine base. (Thompson, supra, 141 Cal.App.4th at p. 1315.) Thompson sought pretrial Pitchess discovery of the records of 11 officers who were involved in the operation. He claimed that he did not sell drugs to the officer and the officers did not recover any "buy" money from him. He claimed that he was in the area where the officers were making arrests, and the officers fabricated the events when they realized he had a prior criminal history. (Thompson, supra, at p. 1317.) The trial court concluded that Thompson had failed to establish good cause and denied his Pitchess motion without conducting an in camera review. (Thompson, supra, at p. 1316.) The ruling was upheld on appeal. The Thompson court recognized that under some circumstances the mere denial of facts described in a police report is sufficient to establish a plausible factual foundation, but that Thompson's factual scenario was not plausible because it was not internally consistent or complete. (Id. at p. 1316.) The court explained: "We do not reject Thompson's explanation because it lacked credibility, but because it does not present a factual account of the scope of the alleged police misconduct, and does not explain his own actions in a manner that adequately supports his defense. Thompson, through counsel, denied he was in possession of cocaine or received $ 10 from the undercover officer. But he does not state a nonculpable explanation for his presence in an area where drugs were being sold, sufficiently present a factual basis for being singled out by the police, 2 or assert any 'mishandling of the situation' prior to his detention and arrest. Counsel's declaration simply denied the elements of the offense charged." (Id. at p. 1317.) The court further explained: "Thompson is not asserting that officers planted evidence and falsified a police report. He is asserting that, because he was standing at a particular location, 11 police officers conspired to plant narcotics and recorded money in his possession, and to fabricate virtually all the events preceding and following his arrest." (Id. at p. 1318.)