Plaintiff, INENA TATEM, as Administrator of the Estate of MICHEAL MARMONKNOCKETT, deceased, moves for judgment against the defendants, CITY OFVRIGINIA BEACH (³VIRGINIA BEACH´), HEATHER M. BOYD (³BOYD´), JOHN DOE#1 (³DOE #1´), JOHN DOE #2 (³DOE #2´), pursuant to Sections 8.01-50 and 64.1-75 of the Code of Virginia, 1950, as amended, both jointly and severally, on the grounds andin the amount set forth as follows:1. Plaintiff qualified and was duly appointed administrator of the estate of Michael Marmon Knockett, deceased, by the Circuit Court Clerk of the City of Virginia Beach on the 29
day of July 2010.2. Plaintiff duly filed and served Notice of Claim pursuant to Virginia CodeSection 15.2-209, 1950, as amended, upon VIRGINIA BEACH on August 13,2010, as required by statute.3. VIRGINIA BEACH is a municipal corporation, who is responsible for theoperation and management of the Department of Public Works, to include thehiring, supervision, and training of its personnel, and the establishment of thepolicies and procedures under which the personnel perform their functions.VIRGINIA BEACH is vicariously liable for the conduct of its personnel whileacting in the scope of their employment.