discussed Cited "see" Linda Gilbert v. John D. Ferry, Jr. See Graves v. Warner Bros., 469 Mich. 853 , 669 N.W.2d 552 (2003), cert. denied, — U.S. —, 124 S.Ct. 2884 , 159 L.Ed.2d 778 (2004). 3 Moreover, re-litigation of the issue is not required since the issue is one of law and the two actions involve claims that are not substantially unrelated; nor is re-litigation of the issue required as the Plaintiffs did not have a significantly heavier burden of persuasion with respect to the issue in the initial action than in the subsequent action.

discussed Cited "see" Gilbert v. Ferry See Graves v. Warner Bros., 469 Mich. 853 (Mich. Oct. 10, 2003), cert. denied, 124 S. Ct. 2884 (2004).3 Moreover, re-litigation of the issue is not required since the issue is one of law and the two actions involve claims that are not substantially unrelated; nor is re-litigation of the issue required as the Plaintiffs did not have a significantly heavier burden of persuasion with respect to the issue in the initial action than in the subsequent action.