Plaintiff is informed and believes and thereon alleges that defendant,2 ROBERT
individual residing in the County
California, and3 who has executed written contracts
ndemnity in favor
plaintiff as will
more fully described4 hereinafter.
6 ; Venue is proper in the Orange County Superior Court in that plaintiff s informed and7 believes and thereon alleges that defendant, ROBERT
MACLEAN, resides at 20 Waltham Road,8 Ladera Ranch, California 92694.9
At all times herein mentioned, the defendants and each
them, were the agents,servants and employees
he remaining defendants. and were at all times acting within thepurpose and scope
said agency and employment.
The true names and capacities, whether individual, corporate, associate,
1 through Does 20 inclusive, are unknown to plaintiff at this time and,plaintiff therefore sues said defendants by such fictitious names. When the true names andcapacities
said defendants are ascertained, plaintiff will amend this Complaint accordingly.Plaintiff is informed and thereon believes and alleges thereon that each
the said defendantsdesignated as a Doe is in some manner responsible for the events and happenings herein referred toand caused injury and damage proximately thereby to the plaintiffs as herein alleged.
IDENTIFICATION OF DOCUMENTS
Application and Indemnity Agreement ("INDEMNITY AGREEMENT',). Attachedhereto and labeled Exhibit"
is an Application and Indemnity Agreement and said Application andIndemnity Agreement is incorporated by reference as iffully set forth into this Complaint whereverreferenced.