in brief: on the "do's and don'ts" of Does in Pelayo v. J. J. Lee Management Co., Inc.

In Pelayo v. J. J. Lee Management Co., Inc. (May 28, 2009) the Court of Appeal (Second Appellate District, Division Four) offered priceless advice on Code of Civil Procedure section 474:  "In this case, we deal with the ―'do's and dont's'of Does."  (Slip op., at 2, first sentence.)  My compliments to Justice Willhite on that opening.  If you are planning on seeking a default judment against a Doe Defendant any time soon, be sure to read this opinion on a narrow matter of procedure.