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i <br /> 1 4. Plaintiffs are informed and believe and thereon allege that Defendant Thoma <br /> 2 DeArth ("DeArth") is, and at all relevant times was, an individual residing in the City of Ripon <br /> 3 County of San Joaquin, State of California. Plaintiffs are further informed and believe an <br /> 4 thereon allege that DeArth is a Member and President of Defendant Genesis Engineering <br /> 5 Redevelopment, LLC. <br /> 6 5. Plaintiffs are informed and believe and thereon allege that Defendant Genesi <br /> 7 Engineering & Redevelopment, LLC ("Genesis") is, and at all relevant times was, a Delaware <br /> 8 limited liability company whose principal place of business is located in Ripon, California. <br /> 9 6. Plaintiffs are ignorant of the true names and capacities of those Defendants sue <br /> 10 herein as Does I through 50, inclusive, and therefore sues these Defendants by such fictitiou <br /> 11 names. Plaintiffs will seek to amend this Complaint when their true names and capacities are <br /> 12 ascertained. Plaintiffs are informed and believe and thereon allege that these fictitiously name <br /> 13 Defendants are in some manner legally responsible, in part or in whole, for the events <br /> 14 transactions, damages and injuries sustained by Plaintiffs as herein alleged. <br /> 15 7. Plaintiffs are informed and believe and thereon allege that at all relevant time <br /> 16 each of the Defendants was the agent or employee of each of the remaining Defendants, and i <br /> 17 doing the things hereinafter alleged, was acting within the course and scope of such agency o <br /> 18 employment, or with the permission and consent of its Co-Defendants. <br /> 19 JURISDICTION AND VENUE <br /> 20 8. Venue is proper pursuant to Code of Civil Procedure section 395 because <br /> 21 Defendants Coldani and DeArth are individuals residing in San Joaquin County, California an <br /> 22 because the injury complained of occurred in San Joaquin County. <br /> 23 9. Venue is further proper pursuant to Code of Civil Procedure section 395.5 <br /> 24 because Defendant Genesis is a limited liability company with its principal place of business i <br /> 25 the City of Ripon, San Joaquin County, California and because the liability arose in the City o <br /> 26 Lodi, San Joaquin County, California. <br /> 27 <br /> c-- <br /> 28 <br /> I-ILRUM`-CRABTREE <br /> 2 <br /> COMPLAINT FOR TEMPORARY RESTRAINING ORDER,PRELIMINARY AND PERMANENT <br /> INJUNCTION,LIBEL PER SE,AND LIBEL PER QUOD <br />