VERITY HEALTH SYSTEM OF CALIFORNIA, INC., a Califo v. Chaudhuri, M.D., an individual

I. Background

Plaintiffs seek authorization to file the following materials under seal:

1) An August 13, 2018 letter from Strategic Global Management, Inc. (“SGM”) to the Plaintiffs (the “Letter”), containing information regarding SGM’s access to liquidity available in connection with SGM’s offer to purchase certain of the hospitals operated by the Plaintiffs (the “Hospitals”). 2) A non-binding draft term sheet sent by Defendants to Plaintiffs, dated October 3, 2019 (the “Term Sheet”), containing evidence regarding SGM’s ability to finance its purchase of the Hospitals.

Plaintiffs also seek authorization to file under seal paragraphs 42 and 82 of their Complaint for Breach of Contract, Promissory Fraud, and Tortious Breach of Contract (Breach of Implied Covenant of Good Faith and Fair Dealing) (the “Complaint”) [Doc. No. 1]. Paragraphs 42 and 82 contain allegations revealing information set forth in the Letter and Term Sheet. Plaintiffs state that they are seeking to file the materials under seal in order to avoid litigation regarding the issue, given that SGM designated the materials as “highly confidential” when they were produced. Plaintiffs reserve the right to seek an…