Blizzard Energy v. Schaefers

Filed 11/29/22 CERTIFIED FOR PUBLICATION IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA SECOND APPELLATE DISTRICT DIVISION SIX BLIZZARD ENERGY, INC., 2d Civil No. B314740 (Super. Ct. No. 17CVP-0266) Plaintiff and Appellant, (San Luis Obispo County) v. BERND SCHAEFERS, Defendant and Respondent. We hold that, for purposes of the vexatious litigant statute, a defendant who files a cross-complaint has commenced a separate, distinct, and independent cause of action. Thus, respondent’s cross-complaint in a Kansas action counts as one of the “five litigations” required for a vexatious litigant…