What is the scope of the Counterclaim?

Counsel for the Defendant (Plaintiff by Counterclaim), argues that the Counterclaim is not discrete but is intertwined with the main action. The reason for the termination of the Barnes’ contract was the allegation of fraud, which is the subject matter of the main action. The communication of the allegation of fraud forms the basis for the Counterclaim. Counsel for the Defendant also argues that the defamation action has issues of credibility and disputed facts and is not appropriate for summary judgment: Baglow v. Smith 2012 ONCA 407.