California, United States of America
The following excerpt is from Dryer v. Dryer, 231 Cal.App.2d 441, 41 Cal.Rptr. 839 (Cal. App. 1964):
Respondent maintains that because the actions are between the same parties, involve the identical properties and seek to set aside the transfer procured by an allegedly scheming and corrupt woman from a husband said to be suffering from mental and physical deterioration, the prior judgment is conclusive; the claimed primary wrong is fundamentally the same although there is some difference in the grounds.
In Little v. Smith, 47 Cal.App. 8, 15, 189 P. 1059, 1062, the court stated:
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