Personal Injury Lawyer Blog
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.)
First Amended Complaint for Damages for Sexual Harassment
THE PARTIES
1. PLAINTIFF JANE DOE 1 ( PLAINTIFF DOE 1 ) was at all relevant times herein an individual female residing in the County of Sacramento.
2. PLAINTIFF JANE DOE 2 ( PLAINTIFF DOE 2 ) was at all relevant times herein an individual female residing in the County of Sacramento.
3. PLAINTIFF JANE DOE 3 ( PLAINTIFF DOE 3 ) was at all relevant times herein an individual female residing in the County of Sacramento.
4. PLAINTIFFS are informed and believe and based thereon allege that DEFENDANT STARS, INC. ( DEFENDANT STARS ) was at all relevant times herein a corporation licensed to do business and conducting business in the State of California, and which owns an establishment known as Stars, Sacramento Club, which is a restaurant and gentleman’s club, i.e. a strip club located in Sacramento, California.
5. In the alternative, PLAINTIFFS are informed and believe and based thereon allege that DEFENDANT STARS, INC., dba SAM, INC. ( DEFENDANT STARS ) was at all relevant times herein a corporation licensed to do business and conducting business in the State of California, and which owns an establishment known as Stars, Sacramento Club, which is a restaurant and gentleman’s club, i.e. a strip club located in Sacramento, California.
6. PLAINTIFFS are informed and believe and based thereon allege that DEFENDANT DAVID SMITH is an owner, officer, director and/or manager of Stars, Sacramento Club.
7. The true names and capacities, whether individual, corporate, associate or otherwise, of Defendants sued herein as DOES 1 through 100, inclusive, are currently unknown to PLAINTIFFS, who therefore sue said Defendants by such fictitious names. PLAINTIFFS are informed and believes, and based thereon allege that each of the Defendants designated herein as a DOE is legally responsible in some manner for the events and happenings referred to herein, and caused injury and damage proximately thereby to PLAINTIFF as hereinafter alleged. PLAINTIFF will seek leave of Court to amend this complaint to show the true names and capacities of the Defendants designated herein as DOES when the same have been ascertained.
8. Whenever in this complaint reference is made to Defendants, and each of them, such allegations shall be deemed to mean the acts of Defendants acting individually, jointly and/or severally.
9. PLAINTIFFS are informed and believe and based thereon allege, that at all times mentioned herein, each of the Defendants was the agent, servant and employee, co-venturer and co-conspirator of each of the remaining Defendants, and was at all times herein mentioned, acting within the course, scope, purpose, consent, knowledge, ratification and authorization of such agency, employment, joint venture and conspiracy. (See Part 2 of 7.)
For more information you are welcome to contact Sacramento personal injury lawyer, Moseley Collins.