TRENTON, N.J. - A school board must file its counterclaim for liquidated damages against an insolvent insurer in the insurer's liquidation proceeding, a New Jersey appeals panel affirmed Nov. 12 (American Motorists Insurance Co. v. North Plainfield Board of Education, No. A-2234-12T1, N.J. Super. App. Div.; 2013 N.J. Super. Unpub. LEXIS 2714).