What are two separate actions in the context of a prior action?

California, United States of America


The following excerpt is from Russell v. United Pac. Ins. Co., 25 Cal.Rptr. 1 (Cal. App. 1962):

These two actions find their source in a prior action (Butler v. Holman, 146 Cal.App.2d 22, 303 P.2d 573 cert. den., 353 U.S. 930, 77 S.Ct. 718, 1 L.Ed.2d 723).

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