California Code of Civil Procedure Code § 426.10

Code of Civil Procedure Code
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As used in this article: (a) “Complaint” means a complaint or cross-complaint. (b) “Plaintiff” means a person who files a complaint or cross-complaint. (c) “Related cause of action” means a cause of action which arises out of the same transaction, occurrence, or series of transactions or occurrences as the cause of action which the plaintiff alleges in his complaint.

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