California, United States of America
The following excerpt is from Hancock v. Cnty. of Plumas, C071084 (Cal. App. 2013):
1. The pleading engages in the common loose practice of calling these causes of action without regard to whether each one actually constitutes a separate invasion of a separate primary right, as opposed to counts that state alternative theories of liability. (Cullen v. Corwin (2012) 206 Cal.App.4th 1074, 1076, fn. 1.)
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