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Feinstein Complaint Durkee

Feinstein Complaint Durkee

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Published by gmaddaus
Sen. Dianne Feinstein's complaint against Kinde Durkee, First California Bank
Sen. Dianne Feinstein's complaint against Kinde Durkee, First California Bank

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Published by: gmaddaus on Sep 23, 2011
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10/24/2011

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22.At all times relevant to this Complaint, Defendants, and each of them,

were acting as the agents, servants, employees, joint venturers, and/or

representatives of each other, and were acting within the course and scope of their

agency, employment and/or joint venture, with the full knowledge, consent,

permission, authorization and ratification, either express or implied, of each of the

other Defendants in performing the acts alleged in this Complaint.

23.Defendants, and each of them, participated as members of a

conspiracy and/or aided and abetted one another in furtherance of the schemes

herein alleged, or assisted one another in carrying out the purpose of the conspiracy

alleged herein, and have performed acts and made statements in furtherance of the

conspiracy in violation of California law. Each of the Defendants acted both

individually and in concert with the other Defendants with full knowledge of their

respective wrongful conduct. As such, the Defendants conspired together, building

upon each other’s wrongdoing, in order to accomplish the acts outlined in this

Complaint. Defendants are individually sued as principals, participants, and/or as

aiders and abettors in the wrongful conduct complained of, and the liability of each

arises from the fact that each has engaged in all or part of the improper acts, plans,

schemes, conspiracies, or transactions complained of herein.

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