The New Jersey Appellate Division upheld the grant of summary judgment to a real estate holding company in a personal injury action, holding that a plaintiff cannot employ the fictitious party rule after the expiration of the statute of limitations unless it can demonstrate that identification was not readily discoverable sooner.

Alexa Baez-Zucco was walking in a Walgreens parking lot on May 23, 2018, when she slipped and fell on some loose gravel, injuring her ankle. Police responded to the scene and created an accident report that stated the location of her fall as 20 Arnot St. in Lodi, which was owned by Walgreen Eastern Co. Inc., according to the opinion.