Can an agent or employee of an insurance company become a named party in the action?

In distinguishing dicta from another case, we once noted that allegations of an agency relationship could prevent us from dismissing Does as shams. See Hartwell, 678 F.2d at 843-44 (distinguishing Preaseau v. Prudential Ins. Co., 591 F.2d 74, 77 n. 2 (9th Cir.1979)). In Preaseau, however, the complaint alleged that an insurance company, or its agents or employees, had wrongfully denied insurance coverage to the plaintiff. 591 F.2d at 75, 77 n. 2. Given the nature of the cause of action, it was not difficult to see how an agent or an employee of an insurance company might become a named party at a later point in the proceedings.