Shropshire v. Ocean Avenue CA2/4
Under Code of Civil Procedure section 474, a plaintiff who is ignorant of a defendant’s identity may designate the defendant in a complaint by a fictitious name (typically, as a “Doe”), and subsequently amend the pleading to state the defendant’s true name when the plaintiff later discovers it.1 If the plaintiff seeks to name a defendant under section 474 after the statute of limitations has lapsed, the amendment will relate back to the
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