How have courts interpreted the doctrine of 'right to know' in the context of a lawsuit?

13 That the public's adversary in litigation may wrap himself in the banner of the public's right to know is illustrated by the following observation in Jessup v. Superior Court, supra, 151 Cal.App.2d at pages 107--108, 311 P.2d at page 181: 'Here Sanders is not desirous of seeing these reports as a citizen primarily interested in protection of the public; he is desirous of seeing them in the hope that he may gain some advantage therefrom in his contemplated suit against the city, making disclosure a possible disadvantage to the city. Thus the public welfare requires that inspection be postponed until disclosure will no longer be of disadvantage to the city.'