Colorado Code § 15-12-811

Counterclaims
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In allowing a claim the personal representative may deduct
any counterclaim which the estate has against the claimant. In determining a claim against an
estate a court shall reduce the amount allowed by the amount of any counterclaims and, if the
counterclaims exceed the claim, render a judgment against the claimant in the amount of the
excess. A counterclaim, liquidated or unliquidated, may arise from a transaction other than that
upon which the claim is based. A counterclaim may give rise to relief exceeding in amount or
different in kind from that sought in the claim.

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