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T E T I N A
R U N D A
A R R E D
R U C K E R
organized and existing under the laws of the State of California, and having a principal place of business at 829 West 17
Street, Suite 5, Costa Mesa, California 92627. 2.
Upon information and believe, Defendant Single Eagle, Inc. is a corporation organized and existing under the laws of the state of California and is doing business as Concrete Contractors Interstate (“CCI”), having a principal place of business at 12599 Stotler Court, Poway, California 92064. 3.
The true names and capacities of the Defendants named herein as DOES 1-5, whether individual, corporate, associate, or otherwise, are unknown to Lithocrete, who therefore sues said Defendants by said fictitious names. Lithocrete is informed and believes, and thereon alleges, that each of the Defendants designated herein as DOE is legally responsible for the events and happenings hereinafter alleged and legally caused injury and damages proximately thereby to Lithocrete as herein alleged. Lithocrete will seek leave to amend the Complaint when the true names and capacities of said DOE Defendants have been ascertained. CCI and DOES 1-5 are herein collectively referred to as “Defendants”). 4.
Lithocrete is informed and believes, and on that basis alleges, that each of the Defendants participated in and is in some manner responsible for the acts described in this Complaint and any damages resulting therefrom. 5.
Lithocrete is informed and believes, and on that basis alleges, that each of the Defendants has acted in concert and participation with each other concerning each of the claims in this Complaint. 6.
Lithocrete is informed and believes, and on that basis alleges, that each of the Defendants were empowered to act as the agent, servant and/or employees of each of the other Defendants, and that all the acts alleged to have been done by each of them were authorized, approved and/or ratified by each of the other Defendants.
JURISDICTION AND VENUE
This Court has subject matter jurisdiction of this action under 28 U.S.C.