In County of Orange v. Quinn (2002) 97 Cal.App.4th 956, the Court held that the five-year rule does not apply to welfare reimbursement child support actions in which there are pendente lite child support orders. In Quinn we acknowledged that section 583.161 does indeed "unambiguously" extend "immunity from the five-year rule no further than marital dissolution cases." ( Quinn, supra, 97 Cal.App.4th at p. 960.) However, as we then went on to explain, another statute, Family Code section 3601, provides an alternative basis for exempting welfare reimbursement actions from the five-year rule. Referring to section 3601, we said, "Certain ideas have their consequences, and when the Legislature said all pendente lite child support orders are exempted from the five-year rule, it necessarily also said that all cases in which pendente lite child support orders have been obtained are exempted as well." ( Quinn, supra, 97 Cal.App.4th at p. 962.)