In Fireman's Fund Insurance Co. v. Sparks Construction, Inc. (2004) 114 Cal.App.4th 1135, the plaintiff filed a complaint naming Kohler Co. and Does 1-10 as defendants. (Id. at p. 1140.) It thereafter filed a first amended complaint naming two other companies as defendants, but omitting any Doe allegations. (Ibid.) Several months later, after substituting a new attorney, the plaintiff filed an amendment to its first amended complaint purporting to name Sparks Construction (Sparks) as Doe 1. (Ibid.) It served Sparks with copies of its original complaint and with the amendment naming Sparks as a Doe. (Ibid.) Sparks answered with a general denial and various affirmative defenses, but did not assert lack of personal jurisdiction as a defense. (Id. at p. 1141.) One year later, plaintiff sought leave to file a second amended complaint against Sparks and other defendants. (Ibid.) Sparks moved for and was granted judgment on the pleadings on the grounds that (1) at the time Sparks was served in the action there was no operative complaint naming it as a Doe defendant since the original complaint had been superseded by a first amended complaint containing no Doe allegations, and (2) the statute of limitations had run, precluding plaintiff from serving Sparks with a new pleading properly naming it as a defendant. (Id. at pp. 1141-1142.) The Court of Appeal agreed with the trial court's ruling that by filing the first amended complaint containing no Doe allegations, the plaintiff had effectively dismissed all of the Doe defendants. (Fireman's Fund, supra, 114 Cal.App.4th at pp. 1142-1143.) According to the appellate court, the filing of that pleading was equivalent to filing a request for dismissal of all the Doe defendants without prejudice. (Ibid.) Thus, the panel concluded that "when the original summons was served on Sparks . . ., there was no underlying action against it." (Id. at p. 1144.)