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To: Elmer who wrote (54399)	9/10/2001 6:12:48 PM
From: survivin	Read Replies (1) \| Respond to of 275872

Re: As I said before, this is standard procedure when sued. You're entirely correct. When answering a complaint a party must submit counterclaims which arise out of same nucleus of facts or run the risk of being denied the chance to raise it later. This is why a typical answer (and complaint) will raise every conceivable (counter)claim and defense under the sun. Here, it is arguable that Via's claims will raise some entirely new issues so we might see some sandbagging, but given the likelihood of settlement and inherent posturing, all barrels will likely be emptied.