In May 2011, plaintiff Jay Thomas, a medical doctor, signed an employment agreement for a new five-year term, during which he was to perform administrative, research and clinical duties for City of Hope Medical Group Inc., and serve as Chair of the Department of Supportive Care Medicine at City of Hope National Medical Center. He was originally hired on July 1, 2008, when he signed a prior five-year written employment agreement. However, within days of his signing the 2011 contract, Thomas was asked to resign, and proceedings were begun to remove him from his role as chairperson pursuant to medical staff bylaws. Thus, in August 2011, Thomas was removed from his role. Thomas sued the City of Hope National Medical Center and the City of Hope Medical Group Inc. Thomas alleged that the defendants’ actions constituted promissory fraud, a breach of covenant of good faith, and defamation. The matter proceeded to arbitration. Thomas claimed that when the defendants offered him the 2011 agreement, they entered into the contract with no intent to perform. He also claimed the defendants were “calling around” to colleagues and authorized an executive recruiting firm to send an email to professionals, seeking to find candidates before he was removed as chair. Thomas alleged that the defendants’ actions in seeking to find candidates to replace him prior to his removal were defamatory. Defense counsel contended that prior to the removal of Thomas as chair, the defendants offered intensive counseling efforts to help Thomas succeed in his role, though they were not successful. Counsel also contended that when Thomas entered into the 2011 agreement, he was acutely aware of the potential for his removal as chair. Defense counsel contended that this, coupled with the fact that Thomas was offered the new 2011 agreement along with virtually every other doctor, showed that there was no intent to deceive Thomas about whether he was at risk of losing the Department Chair position. With regards to Thomas’ defamation claim, counsel asserted that neither the City of Hope National Medical Center nor the City of Hope Medical Group ever made any disparaging statements about Thomas., Thomas sought recovery of consequential and punitive damages for the alleged defamation, promissory fraud, and breach of the covenant of good faith. Defense counsel asserted that Thomas did not suffer any damages because Thomas was never rejected from any open position for which he applied as a result of any alleged statements made by the City of Hope National Medical Center or the City of Hope Medical Group, or by any executive recruiting him. Counsel further asserted that Thomas voluntarily left his employment at City of Hope.