In Roseleaf Corp. v. Chierighino, 59 Cal. 2d 35, 378 P.2d 97, 98, 27 Cal. Rptr. 873 (Cal. 1963), where a sold-out junior lienor's security was rendered valueless by the senior lienholder's non-judicial foreclosure, the Supreme Court of California held that the "one form of action" rule of section 726 of the California Civil Procedure Code did not apply to a sold-out junior lienor since "there is no reason to compel a junior lienor to go through foreclosure and sale when there is nothing left to sell." Roseleaf, 378 P.2d at 99. The court stated that the junior lienor "is in no better position to protect himself than is the debtor; either would have to invest additional funds to redeem or buy in at the sale and equitable considerations favor placing this burden on the debtor. . . ." Id. at 100.