California, United States of America
The following excerpt is from Banyan Ltd. P'ship v. Baer, G045584 (Cal. App. 2013):
The equitable postjudgment procedure permitted by Code of Civil Procedure section 187 is not simply an alternative means of litigating an issue pleaded in the complaint against a named party to the action. Indeed, cases have held that when a judgment creditor was aware of alter ego relationship before trial, amendment of the judgment to add the known alter ego was not appropriate. In Jines v. Abarbanel (1978)
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