capacity. Plaintiff is informed and believes, and thereon alleges, that at all times herein concerned,said defendant was licensed to do business in, and was doing business in, the County of LosAngeles, State of California. Plaintiff is informed and believes and thereon alleges thatASSOCIATION FOR BETTER LIVING AND EDUCATION owned, operated, managed or wasotherwise involved with NARCONON.4. Plaintiff is informed and believes and thereon alleges that at all times hereinconcerned, defendant PHIL ARMOUR was an individual who was a resident of the County of LosAngeles, State of California. Said defendant was employed by NARCONON at all material times.5. Plaintiff is informed and believes and thereon alleges that at all times hereinconcerned, defendant JEANNIE TRAHANT was an individual who was a resident of the Countyof Los Angeles, State of California. Said defendant was employed by NARCONON as itsexecutive director at all material times.6. Plaintiff is ignorant of the true names and/or capacities, whether individual,corporate, associate, or otherwise, of defendants DOES 1-50, so plaintiff therefore sues saiddefendants by such fictitious names. Plaintiff is informed and believes, and thereon alleges, that
each of these DOE defendants is legally responsible in some manner for the events and happeningsherein referred to, and legally caused injury and damages thereby to plaintiff as herein alleged.7. That at all times hereinmentioned, defendants, and each of them, were the agents,servants, and/or employees of each of the remaining defendants, and were at all times actingwithin the purpose and scope of said agency, service and/or employment, and that each defendanthas ratified and approved the acts of his, her or its agent, servant and/or employee.8. On or about April 5, 1995, plaintiff was hired as an employee of NARCONONpursuant to a written contract of employment. The term of that contract was 2-1/2 years. Theterms of that contract were that plaintiff was to perform duties as an employee of NARCONONfor that 2-1/2 year period. Plaintiff was then made an administrative supervisor which is anexecutive position at NARCONON with defendant JEANNIE TRAHANT as his superior. Thiswas the position plaintiff held until he was discharged by NARCONON.