Excerpt: I recently noted what appears to be a tendency in disability cases to permit counterclaims against benefit claimants to proceed without significant analysis of the counterclaims' theoretical basis. (See, :: Seventh Circuit Holds That Sereboff Supports Disability Carrier's Counterclaim) In the recent decision in Raybourne v. Cigna, however, the court gives the issue more detailed analysis and is therefore worthy of note.

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