The Regents - University of California | Office of The President

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pursuant to Code of Civil Procedure § 474. Plaintiff further alleges that each of
said fictitious Doe Defendants are in some manner responsible for the acts and
occurrences hereinafter set forth. Plaintiff will amend this Complaint to show
their true names and capacities when the same are ascertained, as well as the
manner in which each fictitious Defendant is responsible for the damages
sustained by Plaintiff.
4. Agents and Co-Conspirators
23. At all relevant times, each Defendant was and is the agent of each of
the remaining Defendants, and in doing the acts alleged herein, was acting within
the course and scope of such agency. Each Defendant ratified and/or authorized
the wrongful acts of each of the Defendants.
24. Defendants, and each of them, are individually sued as participants
and as aiders and abettors in the improper acts, plans, schemes, and transactions,
to induce Plaintiff to purchase the stock that is the subject of this Complaint.
25. Defendants, and each of them, have participated as members of the
fraud or acted with or in furtherance of it, or aided or assisted in carrying out its
purposes alleged in this Complaint, and have performed acts and made statements
in furtherance of the violations and conspiracy.
5. Unnamed Participants
26. Numerous individuals and entities participated actively during the
course of and in furtherance of the conspiracy to recognize false revenues for
WorldCom, and conceal such information from the public. There was a
conspiracy and many acts were done in the course of and in furtherance of the
conspiracy by statements, conduct, and intent to defraud. The individuals and
entities acted in concert by joint ventures and by acting as agents for principals, in
order to advance the objectives of the conspiracy to increase false revenues. The
acts were intended to promote the conspiratorial objectives.
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COMPLAINT