California, United States of America
The following excerpt is from Gilmore v. Gilmore, 282 P.2d 598 (Cal. App. 1955):
In Smith v. Smith, 21 N.J.Misc. 273, 33 A.2d 684, the general rule was upheld. However, it was pointed out that the filing of such a supplemental pleading was merely an irregularity which the parties could waive, and also that a supplemental pleading
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