Higgins v. Superior Court, No. D071353 (D4d1 Sept. 28, 2017)
P filed a complaint in May 2012. She named D1 and a bunch of Does, serving D1 soon thereafter. D1 proceeded to go Chapter 7, staying P’s case. Two-and-a-half years later, the bankruptcy case was discharged, lifting the stay. Based on stuff she claims to have learned during the BK case, P subbed in D2 for a Doe and served her in August 2016.