The "
Oxford English Dictionary
" states that John Doe is "the name given to the fictitious lessee of the plaintiff, in the (now obsolete) mixed action of
ejectment,
the fictitious defendant being called Richard Roe". (Note that this is in marked contrast to current
Nuttall Encyclopaedia
" states that John O'Noakes, or John Noakes, is a fictitious name for a litigious person, used by lawyers in actions of ejectment.)