California, United States of America
The following excerpt is from Helling v. Lew, 104 Cal.Rptr. 789, 28 Cal.App.3d 434 (Cal. App. 1972):
2 The harsh results inherent in this rule are mitigated by the fact that a plaintiff who knows of other heirs and fails to join them is liable for the resulting damage. (Watkins v. Nutting, supra, 17 Cal.2d at p. 499, 110 P.2d 384.)
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