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.