Legal Counterclaim Finder identifies viable counterclaims, crossclaims, and third-party claims from a defendant's perspective. Given a complaint and the defendant's facts, it identifies all causes of action the defendant can assert against the plaintiff (compulsory and permissive counterclaims) or third parties.

Maximizes the defendant's offensive litigation position per the DAMAGES MAXIMIZATION mandate.

Intended Use

Primary: Identify all counterclaims when answering a complaint
Secondary: Find crossclaims and third-party complaint opportunities
Integration: Called during GLACIER Stage 2/3 when the case posture is defensive

Task Type

text-generation -- Counterclaim and crossclaim identification and drafting

Base Model

meta-llama/Llama-3.1-8B-Instruct -- Strong reasoning for complex multi-party analysis

Training Data

Source	Records	Description
Counterclaim Filings	~200K	Filed counterclaims with outcomes
Crossclaim Filings	~50K	Filed crossclaims
Third-Party Complaints	~100K	Impleader actions
FRCP Rule 13 Analysis	~30K opinions	Compulsory vs. permissive counterclaim rulings
FL Rule 1.170 Analysis	~10K opinions	Florida counterclaim rules
Successful Counterclaim Outcomes	~100K	Cases where counterclaims resulted in recovery

Counterclaim Categories

Compulsory (FRCP 13(a)): Same transaction or occurrence -- must be asserted or waived
Permissive (FRCP 13(b)): Different transaction -- may be asserted at option
Crossclaim (FRCP 13(g)): Against co-party on same transaction
Third-Party (FRCP 14): Impleader for contribution/indemnity
Setoff: Offsetting damages against plaintiff's claim

Output Format

COUNTERCLAIM ANALYSIS:

COMPULSORY COUNTERCLAIMS (must file or waive):
1. [Cause of Action] against [Plaintiff]
   Elements: [mapped to available facts]
   Damages: [estimated recovery]
   Authority: [case law support]

PERMISSIVE COUNTERCLAIMS (recommended):
1. [Cause of Action] against [Plaintiff]
   Strategic value: [why this helps]

THIRD-PARTY CLAIMS:
1. [Cause of Action] against [Third Party]
   Basis: contribution / indemnity / direct liability

TOTAL POTENTIAL RECOVERY: $X

Benchmark Criteria (90%+ Target)

Metric	Target	Description
Compulsory Counterclaim Recall	>= 95%	Must identify all compulsory counterclaims (waiver risk)
Viable Counterclaim Precision	>= 85%	Identified counterclaims must be legally viable
Element Support	>= 80%	Facts must support the identified counterclaim elements
Damages Estimation	>= 75%	Reasonable damage estimate for each counterclaim
Third-Party Identification	>= 85%	Correctly identify contribution/indemnity targets

GLACIER Pipeline Integration

STAGE 1 (Classify) --> case posture identified as defensive
STAGE 2 (Research) --> counterclaim-finder identifies all potential counterclaims
STAGE 3 (WDC #1) --> counterclaims validated by Legal Bench and Red Team
STAGE 4 (Draft) --> counterclaims drafted into answer filing
STAGE 5 (WDC #2) --> verify compulsory counterclaims not omitted

Training Configuration

LoRA fine-tuning (r=16, alpha=32)
Epochs: 3
Learning rate: 1e-4
Max sequence length: 8192
Hardware: AWS SageMaker ml.g5.12xlarge

Limitations

Complex multi-party cases with many potential crossclaims are challenging
Insurance and indemnity relationships may not be apparent from the complaint alone
Does not assess collectability of counterclaim damages
Permissive counterclaim strategy depends on case-specific factors

Version History

Version	Date	Notes
v0.1	2026-04-10	Initial model card, repo created