I'm sure Judy will chime in, but... I've seen several cases like this, especially in mineral royalties or land quiet title. They use the known names; there may not be evidence or knowledge that the subjects are now deceased. Sometimes they add stuff like "Jane Doe, or her heirs" in the original to cover bases. The suit is adjusted as the status of subjects becomes known during the discovery process. My experience has been there are several kinds of adjustments - Jane Doe, Estate of, etc. Dee - - - Dee Dee King, Certified Genealogist (sm), Certificate 903 Contract Genealogist, US Navy POW/MIA Branch Mail address - PO Box 1085, Manvel TX 77578 Telephone/fax 281-595-3090 www.forensicgenealogyservices.com www.facebook.com/forensicgenealogist Certified Genealogist (CG) is a service mark (sm) of the Board for Certification of Genealogists®, conferred to associates who consistently meet ethical and competency standards in accord with peer-reviewed evaluations every five years, and the board name is registered in the US Patent & Trademark Office.