(Please note: the names and locations of all parties have been changed to protect the confidentiality of this car accident case and its proceedings.)
Complaint for Damages: 1) Breach of Contract; and 2) Breach of Implied Covenant of Good Faith and Fair Dealing
1. Plaintiff ANNA A. (hereinafter “Anna” ) is, and at all times mentioned herein, was an individual and a resident of the County of Sacramento, State of California.
2. Plaintiff SUZY B. (hereinafter “Suzy” ) is, and at all times herein, was an individual and a resident of the County of Sacramento, State of California, and is one of Anna’s daughters.
3. Plaintiff VICKIE C. (hereinafter “Vickie” ) is, and at all times mentioned herein, was an individual and a resident of the County of Sacramento, State of California. Vickie is also a daughter of Anna. Unless specifically referred to by name, each of the above mentioned plaintiffs will be collectively referred to herein as Plaintiffs.
4. Plaintiffs are informed, believe, and based thereon allege, that Defendant XYZ INSURANCE CO. OF NORTHERN CALIFORNIA (hereinafter “XYZ” or “Defendant” ) is, and at all times mentioned herein, was a corporation licensed to do business and actually doing business as an insurer and issuing insurance policies in the State of California, with its principal place of business in Sacramento, CA 95814.
5. Plaintiffs are unaware of the true names and capacities of those defendants sued herein as DOES 1-20. However, Plaintiffs will seek leave to amend this complaint when the true names and capacities of these defendants are ascertained. Plaintiffs are informed and believe and based thereon allege, that said fictitiously named defendants are legally responsible in some manner for the injuries and damages alleged herein.
6. Plaintiffs are informed, believe, and based thereon allege, that at all times mentioned herein, defendants, and each of them, were the agents, servants, and employees of the other co-defendants and were authorized to do the things alleged, or were acting within the course, scope, purpose and authority of said agency and employment in performing the conduct alleged herein. Plaintiffs are further informed, believe, and based thereon allege, that each and every defendant when acting as a principal, was negligent in the selection and/or hiring of each and every other defendant as agent, servant, and employee and/or ratified the actions set forth herein in acting in regard to this complaint.
7. Venue is proper with this Court as the events which are the underlying subject of this litigation occurred in the County of Sacramento, State of California. (See Part 2 of 6.)
For more information you are welcome to contact Sacramento personal injury lawyer, Moseley Collins.