8. If defendant’s answer contains a counterclaim, must plaintiff assert a compulsory counterclaim to defendant’s counterclaim? Does it matter whether defendant’s counterclaim is compulsory or permissive? Is a counterclaim to a counterclaim likely to be so confusing that it will prevent the orderly disposition of the case? Would it make any difference if plaintiff amended the complaint to include the claim rather than asserting it as a counterclaim? See Millar, Counterclaim Against Counterclaim, 48 Nw. U.L. Rev. 671, 690 (1954).