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I actually do them on a random occasion and have in OOTP in the past.
Three-team trades aren't -- even in real life -- three-team trades. So, what you would have to do is make a deal like you would normally and then take one of the players you just received in the deal and deal that player elsewhere immediately. That's a three-team deal by definition.
So, you wouldn't even have to use commish mode to do it in theory.
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