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3 <br />1-10, are sued herein under fictitious names for the reason that, after thoroughly investigating <br />the facts of the action, said Defendants' true names and identities are presently unknown to <br />Plaintiff, except upon information and belief, that they are connected in some manner with <br />the named Defendants and/or were the agents, servants, employees, employers, <br />representatives, co -venturers, associates, vendors, suppliers, manufacturers, distributors, <br />subcontractors or contractors and/or owners, lessees, assignees, licensees, of the named <br />Defendants and/or were in some manner presently unknown to the Plaintiff engaged in the <br />activities alleged herein and/or were in some manner responsible for the injuries or damages <br />to Plaintiff which was a proximate cause of injuries or damages to Plaintiff and that their <br />"true names, identities, capacity, activities and/or responsibilities" are presently unknown to <br />Plaintiff or his attorney. To ascertain the full names and identities of Defendants DOE <br />PERSONS 1-10, DOE CORPORATIONS 1-10, DOE PARTNERSHIPS 1-10, ROE "NON- <br />PROFIT" CORPORATIONS 1-10, DOE UNINCORPORATED ORGANIZATIONS 1-10 <br />and ROE GOVERNMENTAL ENTITIES 1-10, Plaintiff's counsel has investigated the facts <br />alleged herein through inter alia, interview of the Plaintiff and records and files submitted by <br />Plaintiff. When the true names and capacities are ascertained, through appropriate discovery, <br />Plaintiff will move to amend his Complaint to state the true names. <br />II. JURISDICTION AND VENUE <br />1. Plaintiff reiterates and incorporates by reference the preceding paragraphs of this <br />Complaint as though set forth fully herein. <br />2. All of the events done by all of the above -named Defendants described and material to this <br />Complaint occurred within the Island of Hawaii, County of Hawaii, and within the <br />jurisdiction of the Circuit Court of the Third Circuit, State of Hawaii. <br />-3- <br />EXHIBIT "A" <br />Page 3 of 25 <br />Pg3 <br />