SHORT TITLE:
CASE NUMBER:
4. Each cross-defendant named above is a natural person
except cross-defendant (name): except cross-defendant (name):b.a.
(1) (1) a business organization, form unknowna business organization, form unknown
a corporationa corporation (2)(2)
(3) an unincorporated entity (describe): an unincorporated entity (describe):(3)
(4) (4)a public entity (describe): a public entity (describe):
(5) (5) other (specify):other (specify):
Information about additional cross-defendants who are not natural persons is contained in
Cross-Complaint—Attachment 4.
5. The true names and capacities of cross-defendants sued as Does are unknown to cross-complainant.
Cross-complainant is required to comply with a claims statute, and6.
a.
has complied with applicable claims statutes, or
is excused from complying because (specify):
b.
Cause of Action—Indemnification7.
(NUMBER)
a. Cross-defendants were the agents, employees, co-venturers, partners, or in some manner agents or principals, or both,
for each other and were acting within the course and scope of their agency or employment.
b. The principal action alleges, among other things, conduct entitling plaintiff to compensatory damages against me. I
contend that I am not liable for events and occurrences described in plaintiff's complaint.
c. If I am found in some manner responsible to plaintiff or to anyone else as a result of the incidents and occurrences
described in plaintiff's complaint, my liability would be based solely upon a derivative form of liability not resulting from my
conduct, but only from an obligation imposed upon me by law; therefore, I would be entitled to complete indemnity from
each cross-defendant.
Cause of Action—Apportionment of Fault
8.
(NUMBER)
a. Each cross-defendant was responsible, in whole or in part, for the injuries, if any, suffered by plaintiff.
b. If I am judged liable to plaintiff, each cross-defendant should be required: (1) to pay a share of plaintiffs judgment which is
in proportion to the comparative negligence of that cross-defendant in causing plaintiff's damages; and (2) to reimburse me
for any payments I make to plaintiff in excess of my proportional share of all cross-defendants' negligence.
CROSS-COMPLAINT—Personal Injury,
Property Damage, Wrongful Death
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