From Walker v. THI of New Mexico at Hobbs Ctr., 2011 U.S. Dist. LEXIS 65287 (D. N.M. May 20, 2011):
The authorities have split on the question whether an abuse-of-process counterclaim is a compulsory counterclaim in the action which is allegedly abusive. See Pochiro v. Prudential Ins. Co. of Am., 827 F.2d 1246, 1252 (9th Cir. 1987).
From Walker v. THI of New Mexico at Hobbs Ctr., 2011 U.S. Dist. LEXIS 65287 (D. N.M. May 20, 2011):
The authorities have split on the question whether an abuse-of-process counterclaim is a compulsory counterclaim in the action which is…