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I understand why you want to amend your answer but that does not prevent you from answer the interrogatories on the basis that you will amend the complaint. You can make a motion for leave to amend and seek additional time to answer the interrogatories until the amended answer is filed but if the interrogatory answers are due, you need to respond and you can do so based on your anticipated amended answer. Remember you are dealing with what is called notice pleading. The basis for your counterclaim is already contained in the answer so the other side is already on notice of the claims that will constitute your counterclaim. Unless you have the agreement of the other side or approval of the court, you are obligated to answer the interrogatories when they are due.
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