Acknowledging disagreement on the subject, this decision holds that the rule that the filing of the complaint tolls the statute of limitations for claims that the defendant pleads in a cross-complaint in the same action applies both to compulsory cross-complaints that arise from the same or related transactions and to permissive cross-complaints that arise from unrelated transactions.

California Court of Appeal, Sixth District (Walsh, J.); November 3, 2016; 2016 WL 6520137