There are generally two types of data and information that plaintiffs seek in discovery in civil rights cases. First is incident specific data and second is information that might prove the culpability of the agency or municipality. The Monell rule requires that to win a suit against a government entity, the plaintiff must show a policy, or pervasive practice that is tantamount to policy, that caused the abrogation of the plaintiff's constitutional rights. In turn, Federal discovery rules are designed to eliminate surprise and to require each side to be forthcoming and revealing. Some of the materials which might be available through discovery include personnel files of the defendant police officers; internal affairs, complaint, and discipline files; arrest and charging data; the desk book; internal memoranda; regulations, manuals, and orders; and incident-specific materials. 10 notes