Less often, other surnames ending in -oe have been used when more than two unknown or unidentified persons are named in U.S. court proceedings, e.g., Poe v. Snyder, 834 F.Supp.2d 721 (W. D. Mich. 2011), whose full style is Jane Poe, John Doe, Richard Roe, Robert Roe, Mark Moe, Larry Loe, Degage Ministries, and Mel Trotter Ministries, Plaintiffs, v. Rick Snyder, Governor of the State of Michigan, Bill Schuette, Attorney General of the State of Michigan, Kriste Etue, Director of the Michigan State Police, William Forsyth, Kent County Prosecutor, in their official capacities, Defendants; and Friedman v. Ferguson, No. 87-3758, unpublished disposition, 850 F.2d 689 (4th Cir., 29 June 1988), whose full style is Wilbur H. Friedman, Plaintiff-Appellant, v. Thomas B. FERGUSON, Director, Department of Animal Control, a State Actor, In His Official and Individual Capacities; Brett Boe; Carla Coe; Donna Doe; Frank Foe; Grace Goe; Harry Hoe; State Actors, Advisors To Defendant Ferguson, In Their Official and Individual Capacities (identities currently unknown); Marta Moe; Norma Noe; Paula Poe; Ralph Roe; Sammy Soe; Tommy Toe; Private Individuals Who Conspired With the Foregoing State Actors (identities currently unknown); Roger W. Galvin, Chairman, Animal Matters Hearing Board; Vince Voe; William Woe; Xerxes Xoe; Members of the Animal Matters Hearing Board, State Actors, In Their Official and Individual Capacities (identities currently unknown), Defendants-Appellees.Note that the plaintiff-appellant Friedman represented himself, so his use of fictitious names may not reflect legal custom.
Less often, other surnames ending in -oe have been used when more than two unknown or unidentified persons are named in U.S. court proceedings, e.g., Poe v. Snyder, 834 F.Supp.2d 721 (W. D. Mich. 2011), whose full style is Jane Poe, John Doe, Richard Roe, Robert Roe, Mark Moe, Larry Loe, Degage Ministries, and Mel Trotter Ministries, Plaintiffs, v. Rick Snyder, Governor of the State of Michigan, Bill Schuette, Attorney General of the State of Michigan, Kriste Etue, Director of the Michigan State Police, William Forsyth, Kent County Prosecutor, in their official capacities, Defendants; and Friedman v. Ferguson, No. 87-3758, unpublished disposition, 850 F.2d 689 (4th Cir., 29 June 1988), whose full style is Wilbur H. Friedman, Plaintiff-Appellant, v. Thomas B. FERGUSON, Director, Department of Animal Control, a State Actor, In His Official and Individual Capacities; Brett Boe; Carla Coe; Donna Doe; Frank Foe; Grace Goe; Harry Hoe; State Actors, Advisors To Defendant Ferguson, In Their Official and Individual Capacities (identities currently unknown); Marta Moe; Norma Noe; Paula Poe; Ralph Roe; Sammy Soe; Tommy Toe; Private Individuals Who Conspired With the Foregoing State Actors (identities currently unknown); Roger W. Galvin, Chairman, Animal Matters Hearing Board; Vince Voe; William Woe; Xerxes Xoe; Members of the Animal Matters Hearing Board, State Actors, In Their Official and Individual Capacities (identities currently unknown), Defendants-Appellees.Note that the plaintiff-appellant Friedman represented himself, so his use of fictitious names may not reflect legal custom.