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Can I Take this first step to oppose the plaintiff's Motion for SJ and then if their motion is denied, can I then Motion for SJ on my counterclaim? I will not be able to meet the lawyer until next week and I need to get my response in ASAP. I want to keep my options open. After my response-opposition to their Motion for SJ- would I also have the option of putting in a Motion to Dismiss? Thank You!