What is the difference between a plaintiff and plaintiff in a motor vehicle accident case?

all seek recovery for the same damage,³⁶ which is the determining factor under California's primary rights approach to defining a single cause of action. ( Slater v. Blackwood (1975) 15 Cal.3d 791, 795, 126 Cal.Rptr. 225, 543 P.2d 593 ["the cause of action is based upon the harm suffered, as opposed to the particular theory asserted by the litigant"].) Thus, none of these theories of liability stands independently as a separate cause of action.