California, United States of America
The following excerpt is from Osuna v. Paragon Sys., B296748 (Cal. App. 2020):
A cause of action first asserted in state court may properly be deemed to relate back to claims earlier made in federal court if they arise from the same facts. (See, e.g., Dudley v. Department of Transportation (2001) 90 Cal.App.4th 255, 266.)
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