California, United States of America
The following excerpt is from Marriage of Hilke, In re, 2 Cal.App.4th 433, 3 Cal.Rptr.2d 333 (Cal. App. 1992):
[8 Cal.App.4th 1321] Before any of the property issues were adjudicated, wife died. Thereafter, the administrator of wife's estate substituted into the case. (Code Civ.Proc., 385; Kinsler v. Superior Court (1981) 121 Cal.App.3d 808, 812, 175 Cal.Rptr. 564.)
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