California, United States of America
The following excerpt is from Zimmerman v. Wells Fargo Bank, N.A., 2d Civil No. B275595 (Cal. App. 2017):
Zimmerman argues that she should have been granted leave to amend the complaint to include several new causes of action (i.e., wrongful foreclosure, tortious interference with a contract, and violation of Civil Code section 1788.17). But these causes of action allege violations of the same primary right. (See Bescos v. Bank of America (2003) 105 Cal.App.4th 378, 397 ["additional theories are not 'different wrongs' that give rise to different primary rights . . . but rather are different ways of committing the same wrongs"].) Because these causes of action allege violations of the same primary right, they are barred on abatement grounds.
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