California, United States of America
The following excerpt is from Morelli, In re, 11 Cal.App.3d 819, 91 Cal.Rptr. 72 (Cal. App. 1970):
9 (See 60 A.L.R.2d 1247, where, citing MacDermid v. MacDermid, 116 Vt. 237, 73 A.2d 315, it states: 'The court said however, that in any situation in which contempt proceedings are sought to be predicated upon a suit . . . which was entirely independent and constituted a separate litigation from the matter with which the contempt proceedings are concerned, a new service of process, as in the institution of an original proceeding, would be necessary.')
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