Can a plaintiff designate as a fictitious named defendant in a personal injury case?

State law regarding fictitious-named defendants is applied to complaints originally filed in state court. Cabrales v. The County of Los Angeles, 864 F.2d 1454, 1463-1464 (9th Cir.1988), vacated on other grounds, 490 U.S. 1087 (1989), opinion reinstated by 886 F.2d 235, 236 (9th Cir.1989). California Code of Civil Procedure 474 allows a plaintiff to designate as "doe" defendants those parties whose true identities are unknown at the time the complaint was filed. ¹ There are three circumstances under which the "ignorance" requirement can be satisfied: 1) if the plaintiff is unaware of the defendant's identity, 2) if the plaintiff is unaware of the facts giving rise to its cause of action against the defendant, or 3) if the law does not recognize a cause of action until after the time to file the complaint has lapsed. Snoke v. Bolen, 1 Cal.Rptr.2d 492, 494 (Cal.App.1991).