Justice THOMAS delivered the opinion of the court:
The plaintiff, First Midwest Bank (the Bank), filed this lawsuit against the defendants, Lee A. Sparks and Thomas P. Stepanich, to recover for sums loaned to Sparks. In connection with the transaction, Stepanich cosigned the loan documents on behalf of Sparks. Stepanich filed a counterclaim against the Bank and two of the Bank's employees, Thomas Schwartz and Paul Bouchard, alleging common-law fraud and violations...
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