California and has its principal place of business in Contra Costa County, California. Plaintiff
SSST's current President, Katharine Ryan, is an individual residing in Contra Costa County,
3. Plaintiff is informed and believes and thereon alleges that at all relevant times
Defendant MARK EUGENE THORNTON is an individual residing in Contra Costa County,
specifically 15 New Boston Court, Danville, California 94526. Defendant was the former President
of SSST Corporation.
4. The Defendants named herein as DOES 1 through 20, inclusive, are sued by fictitious
names for the reason that Plaintiff does not presently know their true names and capacities. At such
time as Plaintiff shall ascertain the true names and capacities of any of such fictitiously named
Defendants, leave of court will be sought to substitute the same in this Complaint. At all times
herein mentioned, each of the fictitious Defendants, whether individual, corporate, associate, or
otherwise, were legally responsible in some manner for the events and happenings refelred to herein.
5. At all times relevant to this action, Defendants and each of them, were the agents and
employees of each of the remaining Defendants, and were at all times acting within the purpose and
scope of said agency and employment, and each Defendant has ratified and approved said agency
and employment, and each Defendant has ratified and approved the acts of his agent.
JURISDICTION AND VENUE:
6. This Court has jurisdiction over this action by virtue of Ai-ticle VI Section 10 of the
California Constitution and section 410.10 of the Code of Civil Procedure.
7. Venue is proper in Contra Costa County pursuant to section 395(a) of the Code of
Civil Procedure because, among other things, (i) Defendant THORNTON resides in this County; (ii)
Defendant THORNTON does business in this County; and (iii) the breach of fiduciary duty, fraud,
snd conversion by Defendant THORNTON occurred in this County.