In Cohen v. Hellman Commercial T. & S. Bk. (1933) 133 Cal.App. 758, certain real property in San Bernardino County was held in trust by the defendant bank, and plaintiff, claiming as a trust beneficiary, sued to terminate the trust. The trustor cross-complained to reform the trust agreement to express the alleged understanding of the parties that the trustor was to receive monthly payments which were to be a charge on the property. The action had been brought in another county; the issue of venue of the cross-complaint was not raised in the trial court and therefore was deemed waived. Thus the Cohen court's suggestion, quoted above, that the cross-complaint should be characterized as local is pure dictum. The usefulness of Cohen to the Massaes is further attenuated by the fact that the opinion never expressly says that the court deems the quoted language applicable to the facts before it.