Hi, Margery, and thank you for your prompt response. I am not proceeding on my own, I just would like to understand how this process works; however, I am still confused. I understand the fact that if it's note raised in answer as an affirmative defense that it may be waived. What happens if one just found out that a violation was committed? that's why I would like to know if I have to wait until a final order is given to counterclaim or initiate action in federal court? Can I initiate action in federal court and claim all these omitted facts as causes for relief and include all parties involved? Thanks again.