American State Bank v. Stoltz
In American State Bank v. Stoltz, 345 N.W.2d 365, 367 (N.D. 1984), the Court recognized this state's settled law that a supplementary proceeding in aid of execution is not a new or separate action, but is merely a proceeding in a pending action against a judgment debtor.
The Court said a supplementary proceeding was not an action on the judgment, but was a continuation of, and auxiliary to, the original action. Id.
The Court rejected a judgment debtor's claim the trial court lost personal jurisdiction over him when the judgment was entered.