Plaintiff
2. RUSSELL POOLE (hereinafter referred to as "PLAINTIFF"), is a citizen of the United States. PLAINTIFF was a sworn officer of the Los Angeles Police Department ("LAPD") and employee of the Defendant, CITY OF LOS ANGELES.
Defendants
3. Defendant, CITY OF LOS ANGELES (hereinafter referred to as "DEFENDANT CITY") is a municipal corporation, whose principle place of business is within the state of California, more specifically, the County and City of Los Angeles.
4. Defendant, CHIEF BERNARD PARKS (hereinafter referred to as "DEFENDANT PARKS"), is an employee of the DEFENDANT CITY and conducts business within the State of California, more specifically, the County and City of Los Angeles.
5. Defendant, LIEUTENANT EMMANUEL HERNANDEZ (hereinafter referred to as "DEFENDANT HERNANDEZ"), is an employee of the DEFENDANT CITY and conducts business within the State of California, more specifically, the County and City of Los Angeles.
6. The true name and capacities of Defendants, DOES 1 through 50, inclusive, are unknown to PLAINTIFF at this time, and Plaintiff therefore sues defendants under fictitious names. PLAINTIFF is informed and believes, and on that basis alleges, that each defendant designated as a DOE is highly responsible in some manner for the events and happenings referred to herein, and legally causes the injuries and damages alleged in this complaint. Plaintiff will seek leave of the court to amend this complaint to allege their true names and capacities when ascertained.
7. Each defendant, at all times mentioned herein, separately and in concert, acted or failed to act under color of law and regulations of the State of California. Each defendant, separately, and in concert engaged in conduct which deprived PLAINTIFF of the rights, privileges, and immunities secured to PLAINTIFF by law. Each defendant at all times mentioned herein, were, in doing such acts, acting pursuant to and in furtherance of said conspiracy and each defendant sued herein is jointly and severally liable to PLAINTIFF for the damages alleged herein.
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