4402 REVIEW DENIED Every plaintiff in a wrongful death action has a separate cause of action, the requirement that a single action be filed being merely a procedural rule, and for this reason, an amendment to a wrongful death complaint adding a new plaintiff does not relate back to the original complaint; an amendment adding the name of a new plaintiff to a surviving personal injury complaint does not allege a new liability and therefore does relate back to the original complaint, although it may raise a question of whether the newly added person is a proper plaintiff.CitationSDG&E v SUPERIOR COURT (Death Actions) 146 CA4 1545 [See: CCP 335.1, 366.1, 377.20, 377.30; Norgart v Upjohn 21 C4 383, T/AT 9/99; Rabe v WU 198 C 290; Cross v PG&E 60 C2 690]
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