California, United States of America
The following excerpt is from Newport Harbor Ventures, LLC v. Morris Cerullo World Evangelism, 212 Cal.Rptr.3d 216, 6 Cal.App.5th 1207 (Cal. App. 2016):
As we explained above, an amended complaint relates back to an earlier complaint if the amended complaint is based on the same general set of facts, even if the plaintiff alleges a different legal theory or new cause of action. (Smeltzley v. Nicholson Mfg. Co. , supra , 18 Cal.3d at pp. 934, 936, 136 Cal.Rptr. 269, 559 P.2d 624.) The promissory estoppel cause of action, though a new cause of action, was based on generally the same facts as the prior complaints, related back to those complaints, and therefore was not barred by a two-year statute of limitations.
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