PLAINTIFFS’ SECOND AMENDED COMPLAINT
The United States has been asked to intervene and file suit against DefendantsTejon Mountain Village, Tejon Ranch Corporation and the County of Kern asserting claimsidentical to that described here in this complaint, but has not done so.7.
Defendant COUNTY OF KERN, CALIFORNIA (“County”), is the Lead Agencyfor the Tejon Mountain Village Project (State Clearing House Project #2005101018).8.
Defendant TEJON MOUNTAIN VILLAGE, LLC (“TMV”), is a Delawarelimited liability company, with its principal place of business in the County of Kern, California.TMV is a privately held corporation seeking to develop real property in Kern County, California.Plaintiffs are informed and believe and thereon allege that TMV is in possession of, asserts aninterest in, or claims record title to certain lands in Kern County, California, which are a portionof the reservation and aboriginal lands of the Tribe, as appears more fully elsewhere in thiscomplaint. TMV’s position is adverse to the Tribe.9.
Defendant TEJON RANCH CORPORATION (“TRC”), is a Delawarecorporation with its principal place of business in Kern County, California. Plaintiffs areinformed and believe and thereon allege that TRC is the parent corporation of TMV. Plaintiffsare informed and believe and thereon allege that TMV is in possession of, asserts an interest in,or claims record title to certain lands in Kern County, California, which are a portion of thereservation, and aboriginal lands of the Tribe, as appears more fully elsewhere in this complaint.TRC’s position is adverse to the Tribe.10.
The true names and capacities, whether individual, partner, associate, corporate orotherwise, of the Defendants identified as DOES 1 through 100, inclusive, are unknown toPlaintiffs who therefore sue them by such fictitious names. Plaintiffs are informed and believe,and on that basis allege that each of the Defendants sued herein as a DOE Defendant was, and is,in some manner legally responsible for the events herein described. Plaintiffs will seek leave of Court to amend this Complaint if, and at such time as their true names and capacities areascertained.11.
Plaintiffs are informed and believe, and on that basis allege that at all times hereinmentioned, Defendants, and each of them, were the agents, employees, servants, and
Case 1:09-cv-01977-OWW-SMS Document 133 Filed 04/18/11 Page 3 of 25