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Hi, and Welcome to JustAnswer, My name is Andrea, I am a licensed, practicing Attorney, I have 25 years experience and would be glad to help
The attorneys on JustAnswer are glad to answer questions and give information, but JustAnswer is not a law firm, so we cannot take on client representation and no attorney-client relationship is formed. 1. I am sorry you are being put through all this, but I am sorry to say that any Motion you file in an attempt to have the Court deny his request will be a waste of time. You can put your objection on the record, but the Court routinely grants these motions where a party has moved.2. Your understanding is correct. A counterclaim must be included in your Answer to the Plaintiff's Complaint. if the Court grants you permission to amend your Answer and include a Counterclaim, put in everything you stated and then some. You cannot be penalized for this and the most that the Court can do is strike that part of your Counterclaim to which the Plaintiff objects, and that is only if the Plaintiff objects. If the Plaintiff does not object, then the Plaintiff must Answer. 3. You can request anything you want from the Plaintiff in your "Request for the Production of Documents", as long as they relate to he case.
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