Two patients brought an action against their doctor and the doctor’s employers for sexual assault. The trial court sustained defendants’ demurrer without leave to amend because the plaintiffs alleged separate and distinct assaults during separate and distinct periods, and defendants were improperly joined under CCP § 378. The appellate court affirmed the ruling with regard to the doctor but reversed his employers’ demurrer. Since the allegations charged the employers were negligent in hiring and supervising the doctor, the actions against them arises out of the same series of transactions or occurrences. Moe v. Anderson (Cal. App. Third Dist.; July 11, 2012) 207 Cal.App.4th 826.