all of his .co-sureties '"); Davis Sales v. Central Mfg Corp. of Michigan, 398 S.E.2d 820, 822 (Ga. Ct. App. 1990) (recognizing contribution may exist when the co-sureties signed different instruments guaranteeing the same debt); Dever v. Lee, 373 S.E.2d 224, 227 (Ga. Ct. App. 1988) (stating that "the fact that appellant and appellee were not signatories to the same guaranty agreement but rather signed separate agreements ... is not of consequence [to appellant's claim for contribution]"); Kee v. Lofton, 737 P.2d 55, 58 (Kans. Ct. App. 1987) (concluding that the right to contribution may arise regardless of the fact that the co-sureties signed different instruments guaranteeing the same obligation); D'Alessandra v. Manufacturers Casualty Ins. Co., N.Y.S.2d 564, 568 (N.Y. Sup. Ct. 1951) (<HOLDING>). 8 See also John Norton Pomeroy, EQUITY
holding that the common liability that prompts a cause of action for contribution may arise out of the same instrument or out of different instruments or at different times holding that a plaintiffs claims arise under the statute that provides the federal cause of action he or she alleges holding that an arising out of exclusion applies to claims flowing from or growing out of the excluded activity recognizing that the legislature would not generally use a different meaning for the same word in a legislative provision unless a different purpose was intended holding that a single cause of action arises out of the same set of facts