In a prior post, a recent California Court of Appeal case was described in which the defendant unsuccessfully sought to use as a defense the 10-year statute of repose of California Code of Civil Procedure Section 337.15 in a case involving leakage from a closed landfill. In Pine Terrace Apartments, L.P. v. Windscape, LLC, et al, 2009 Cal. App. LEXIS 23 (1/12/09), the Court of Appeal held that Section 337.15 C.C.P. was also applicable to cross-complaints, as were the exceptions to the application of the statute (e.g., willful misconduct).