Can a plaintiff be sanctioned or dismissed if they name a Doe defendant in a subsequent action?
MultiRegion, United States of America
The following excerpt is from Yavor v. City One Locksmith (In re Real Estate Short Sales Inc.), Adv No: 1:19-ap-01139-GM, Case No.: 1:16-bk-11387-GM (Bankr. C.D. Cal. 2020):
Damjanovic v. Ambrose, 951 F.2d 359 (1991) (unpublished) affirmed dismissal of an action and sanctions when the plaintiff tried to name a Doe defendant in a subsequent action after dismissal of the prior-filed case.
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