California, United States of America
The following excerpt is from Morris v. Alameda Health Sys., A151043, A151412 (Cal. App. 2019):
2. Although plaintiff's original complaint did include Doe allegations, plaintiff did not obtain leave to amend to substitute these defendants for the fictitiously named defendants, nor did he comply with the other requirements for application of the Code of Civil Procedure section 474 relationship-back doctrine. (See Woo v. Superior Court (1999) 75 Cal.App.4th 169, 175-177.)
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