Because, by definition, their identity is anonymous, the presence of Doe defendants in federal diversity-based lawsuits is problematic, particularly where the citizenship of an LLC defendant depends upon the citizenship of Doe defendants. See Rich & Rich P'ship v. Poetman Records USA, Civ. A. No. 08–42–ART, 2008 WL 1868028, at *2 (E.D.Ky. Apr. 24, 2008). Prior to 1988, it was widely accepted that the presence of Doe defendants destroys diversity—irrespective of whether the case was originally filed in federal court or removed from state court.
Although residency is one factor, an allegation of residency alone is insufficient. Rich Rich P'ship v. Poetman Records USA, No. 08-42-ART, 2008 WL 1868028, at *2 (E.D. Ky. Apr. 24, 2008) ("allegations of residency are insufficient to establish citizenship for purposes of diversity jurisdiction."). Thus Plaintiff has not properly identified the citizenship of any member of Emlyn Coal Processing of Minnesota, LLC.