12612 DEC -4 P It 32 I - San Diego Reader

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2. Plaintiff is informed and believes and thereon alleges that defendant EQUUSTRIA
DEVELOPMENT, INC. (hereinafter "Equustria") is a corporation, or other form ofentity, doing business
within the boundaries of the Central Judicial District of San Diego County, California.
3. Plaintiff is informed and believes that defendant MARK R. REMLEY (hereinafter "Remley"),
is an individual, residing in Solana Beach, San Diego County, California, and is the alter ego of defendant
Equustria.
4. Plaintiff is unaware of the true names and capacities of defendants sued herein as Does 1 to 50,
inclusive, and therefore sues these defendants by such fictitious names. Plaintiff will amend this
Complaint to allege their true names and capacities when ascertained. Plaintiff is informed and believes
and thereon alleges that each of the fictitiously-named defendants is responsible in some manner for the
occurrences alleged herein, and that Plaintiffs damages as herein alleged were proximately caused by
their conduct.
5. Plaintiff is informed and believes and thereon alleges that at all times herein mentioned,
defendants, and each of them, were the agents and employees of every other defendant, and each of them,
and in doing the things herein alleged were acting within the course and scope of such agency and with
the permission and consent of their co-defendants.
6. This action is not subject to Civil Code § 1812.10 or Civil Code §2984.4.
7. Plaintiff is informed and believes and thereon alleges that this court is the proper court because
a defendant entered into a contract here, because a defendant lived here when the contract was entered
into, because a defendant lives here now, because the contract was to be performed here, and because a
defendant is a corporation and its principal place of business is here.
8. Plaintiff is informed and believes that the relationship between defendant Equustria and Remley is
such that the Court should disregard the corporate entity of Equustria for all purposes. Plaintiff is
informed and believes that:
(a) Equustria was so dominated, influenced and controlled by Remley that it should
not be recognized as a separate legal entity;
(b) adherence to the fiction of the separate existence of defendant corporation
Equustria underthe circumstances of this case would sanction a fraud and promote
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Complaint