California, United States of America
The following excerpt is from Knodel v. Knodel, 122 Cal.Rptr. 521, 14 Cal.3d 752, 537 P.2d 353 (Cal. 1975):
13 The fact claims remaining unresolved following a particular order were placed in issue pursuant to a cross-complaint does not give rise to an exception to the one-judgment rule except perhaps where the parties to the action and cross-action are not identical. (See Herrscher v. Herrscher (1953) 41 Cal.2d 300, 303, 259 P.2d 901.) Here the parties were not only identical but issues raised by each party by their respective pleadings remained unresolved until the judgment of June 30.
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