The following excerpt is from Malibu Media, LLC v. Does 1 Through 13, No. 2:12-cv-01513 MCE KJN (E.D. Cal. 2012):
6. The use of "Doe" defendants is generally disfavored. Gillespie v. Civiletti, 629 F.2d 637, 642 (9th Cir. 1980). However, a plaintiff should be given an opportunity through discovery to identify such defendants where the identities of those defendants are not be known prior to the filing of a complaint, "unless it is clear that discovery would not uncover the identities, or that the complaint would be dismissed on other grounds." Id.
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