Plaintiffs Paul Scarborough and Premier Medical Transport, Inc. ("Plaintiffs") allege and aver against defendants as follows:

Plaintiffs are the victims of a relentless campaign to destroy their reputations and business. The perpetrators of this scheme are cowards, employing sophisticated methods to hide their tracks and prevent identification. Plaintiffs seek this court's assistance in ending defendants' siege, restoring Plaintiffs' good names, and punishing defendants for their abhorrent behavior.

1. Plaintiff Paul Scarborough ("Scarborough") is an individual residing in Orange County, California.

2. Plaintiff Premier Medical Transport, Inc. ("Premier") is a corporation organized and existing under the laws of the state of California, with its principal place of business in the City of Brea, Orange County, California.

3. Plaintiffs are ignorant of the true names and capacities of the defendants sued herein as Does 1 through 50, inclusive, and therefore sue these defendants by such fictitious names. Plaintiffs will amend this complaint to allege these fictitiously named defendants' true names and capacities when ascertained. Plaintiffs are informed and believe that each of these fictitiously named defendants is responsible in some manner for the occurrences herein alleged, and that the damages herein alleged were proximately caused by the aforementioned defendants. Does 1 through 50 may be collectively referred to herein as "Defendants".

4. Plaintiffs are informed and believe that each of the Defendants is the agent, affiliate, joint venturer, and/or employee of each of the remaining Defendants and in taking the actions hereinafter alleged, each was acting within the course and scope of said agency, employment, and/or joint venture with the advance knowledge, acquiescence, or subsequent ratification of each and every remaining Defendant.

5. Plaintiffs are informed and believe that, at all relevant times, Defendants acted for each other in connection with the conduct hereinafter alleged and that each of them performed the III

acts complained of herein, or breached the duties herein complained of, as agents of each other, and each is therefore fully liable for the acts of the other.

6. This Court has jurisdiction over this action because Plaintiffs reside in, are incorporated in, have their main place of business in and/or conduct business in the State of California, and a substantial portion of the acts, omissions, events and transactions alleged herein occurred within the State of California. Venue is proper in the County of Los Angeles, State of California, because Defendants' injurious actions occurred in the County of Los Angeles, State of California, and because Plaintiffs hereby designate the County of Los Angeles, State of California, as the place of proper venue.

7. Founded in 2008 , Premier (doing business as Premier Ambulance) provides emergency and non-emergency ambulance services throughout Southern California, including within the counties of Los Angeles, Orange, and San Diego.

8. Scarborough is Premier's President. Scarborough has worked in the ambulance services field for over forty (40) years and through his tireless efforts earned a stellar reputation in the relevant community.

9. Under Scarborough's leadership, Premier's business and standing have grown by leaps and bounds. As just one example, in December 2023 , the Commission on Accreditation of Ambulance Services ("CAAS") accredited Premier, an honor bestowed on less than 2% of ambulance companies in Los Angeles County. CAAS accreditation is the gold standard for the ambulance industry.

10. Scarborough also serves as an officer of the Southern California Ambulance Association ("SCAA"), an industry trade group comprised of private emergency and non- emergency ambulance service providers. The SCAA works cooperatively with state and local governments to address issues relevant to the ambulance industry. Scarborough's leadership and work ethic make him a vital and respected member of the SCAA.

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