Tennessee Probate of Tort Claim?

 I was reading some interesting comments this morning on whether a probate claim that sounds in tort has to be filed with the Probate Court in Tennessee.   If your claim sounds in tort; in those types of cases, a single copy of the complaint (under a notice of filing) must be filed in the probate court. See Est. of Patten v. Batchelor, 664 S.W.2d 698, 701 (Tenn. Ct. App. 1983) ("[T]he proper procedure in a case such as this one, as in others sounding in tort, is to put the probate court on notice by filing a copy of the complaint so that final distribution of the estate may be held in abeyance pending conclusion of the tort suit."  (Citation omitted.)); Herring v. Est. of Tollett, 550 S.W.2d 660, 661–62 (Tenn. 1977); see also 2 Jack W. Robinson, Sr. et al., Pritchard on the Law of Wills and Administration of Estates Embracing the Law and Practice in Tennessee § 735, passim (Lexis Advance 2023).

 Further, I would also be remiss not to point out that the ninety days to file a motion to substitute after a suggestion of death is filed can be enlarged on a showing of "cause" (as opposed to the higher standard of "good cause") if the enlargement is requested before the time to act expires. See Tenn. R. Civ. P. 6.02. And such enlargement is to be "allowed liberally" if moved for before the time to act expires. Id., Advisory Comm'n Cmt.