North Dakota Code § 30.1-12-04

(3-104) Claims against decedent - Necessity of administration
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No proceeding to enforce a claim against the estate of a decedent or the decedent's 
successors may be revived or commenced before the appointment of a personal representative. 
After the appointment and until distribution, all proceedings and actions to enforce a claim 
against the estate are governed by the procedure prescribed by chapters 30.1 -12 through 
30.1-23. After distribution, a creditor whose claim has not been barred may recover from the 
distributees as provided in section 30.1 -21-04 or from a former personal representative 
individually liable as provided in section 30.1-21-05. This section has no application to a 
proceeding by a secured creditor of the decedent to enforce the secured creditor's right to the 
secured creditor's security except as to any deficiency judgment which might be sought therein.

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