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Csohan (P) sued United (D) for the proceeds of a life insurance policy on her father. P was the named beneficiary on the policy. P was a resident of San Diego. Two months after the Ohio action was started, D filed an action in interpleader in Los Angeles Superior Court and asked for a preliminary injunction to restrain P from proceeding with her suit in Ohio. D filed that action because the mother of P also made a claim upon the proceeds. On March 27, the Ohio court enjoined D from proceeding with the action in California. D appealed the Ohio decision.

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