With no explanation, chose the best option from "A", "B", "C" or "D". in the earlier proceeding commensurate with those in the subsequent proceeding, Maryland Cas. Co. v. Messina, 874 P.2d 1058, 1062 (Colo.1994), but also that the party against whom collateral estoppel is asserted have had the same incentive to vigorously defend itself in the previous action, Salida Sch. Dist. R-32-J v. Morrison, 782 P.2d at 1166-67; Restatement (Second) of Judgments § 28(5)(c) & emt. j (1982). A party necessarily lacks the same incentive to defend where its exposure to liability is substantially less at the earlier proceeding. Salida, 732 P.2d at 1166-67. In addition to the amount of potential money awards, significant variations in exposure may arise from differences in the finality or permanence of judgments, see In re C.M., 675 N.E.2d 1134, 1137-38 (Ind.Ct.App.1997) (<HOLDING>); In re Frederick, 405 Mass. 1, 537 N.E.2d

A: holding that consortium is not a part of the parentchild relationship
B: recognizing that parents incentive to defend in a child in need of supervision proceeding where resulting order is temporary in nature and entitles parent and child to government services is dramatically different from incentive to vigorously litigate same issues in parentaltermination proceeding where the result is permanent and completely severs parentchild relationship
C: holding when real estate is conveyed to a child and consideration is paid by the parent the presumption is that the purchase was a gift to the child and thus no resulting trust arises
D: holding that a workers compensation proceeding is a legal proceeding
B.