California, United States of America
The following excerpt is from J. C. Penney Co. v. Westinghouse Elec. Corp., 217 Cal.App.2d 834, 32 Cal.Rptr. 172 (Cal. App. 1963):
'In 1957, section 442 of the Code of Civil Procedure was amended to permit a cross-complaint to be filed against any person whether or not a party to the original action. In Roylance v. Doelger, 57 Cal.2d 255, 19 Cal.Rptr. 7, 368 P.2d 535, the court carefully reviewed the prior decisions and held that as a result of this amendment a cross-complaint in the nature of an action for declaratory judgment might be filed, bringing in a person against whom a defendant and cross-complainant claimed a right of indemnity. * * *
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