3. Plaintiff is informed and believes, and based thereon alleges that Defendant DAN BLACK, (hereinafter “BLACK”) is an individual who at all relevant times herein was a resident of the County of Sacramento. Plaintiff is informed and believes that at all relevant times herein BLACK was Defendant HBZT’s Nighthawk’s bar manager, a managing agent of Defendant HBZT.
4. The true names and capacities, whether individual, associate or otherwise, of Defendants sued herein as DOES 1 through 50, inclusive, are currently unknown to Plaintiff, who therefore sues said Defendants by such fictitious names. Plaintiff is informed and believes, and based thereon alleges, 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.
5. Whenever in this complaint reference is made to “Defendants, and each of them,” such allegation shall be deemed to mean the acts of Defendants acting individually, jointly, and/or severally.
6. Plaintiff is informed and believes, and based thereon alleges, 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.
7. Plaintiff is female and is employed as a bartender at Defendant HBZT’s Nighthawk bar in East Sacramento, California. She began in February 2008 and was never late, never called in sick, had perfect attendance and performed her job well at all times. (See Part 3 of 8.)
For more information you are welcome to contact Sacramento personal injury lawyer, Moseley Collins.