Defendant, [name of alleged agent], was an agent of the Defendant [name of alleged principal], and was acting in the course of [name of alleged agent’s] employment and within the scope of [name of alleged agent’s] authority at the time of the mishap.

In this case, [the name of principal] is responsible to third persons for the negligence of [the name of the agent] in transacting the business of the agency, including wrongful acts committed by [the name of the agent] in and as a part of transacting the business.

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