What is the effect of the section 998 offer on a complaint and cross-complaint?

California, United States of America

The following excerpt is from Horn v. Rand, B255051 (Cal. App. 2015):

Horn dedicates much of his appellate briefs to the argument that the section 998 offer on the complaint and cross-complaint should have been considered "one offer" in determining its reasonableness. Horn's fails to cite any case law to support his contention and we find the case law inapposite to his position. Generally, a complaint and cross-complaint are treated as independent actions. (Westamerica Bank v. MBG Industries, Inc. (2007) 158 Cal.App.4th 109, 134.) Therefore, the resolution of Horn's

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