prejudiced.” Asbill v. Housing Auth. of Choctaw Nation, 726 F.2d 1499, 1504 (10th Cir.1984). We have implied approval of this harmless error approach in other cases, analyzing whether an error in one of multiple claims submitted to the jury was harmless. See Fleet Nat’l Bank v. Anchor Media Tel., Inc., 45 F.3d 546, 555 (1st Cir.1995) (while the invalid claim “was not the primary focus of lappellee’s] case,” counsel mentioned it in opening and closing arguments and'called a witness specifically to testify to this aspect of the case); Kassel v. Gannett Co., 875 F.2d 935, 950 (1st Cir.1989) (“In this instance, we cannot say the error was harmless. A substantial amount of plaintiffs proof addressed the [erroneous claim]”); Brochu v. Ortho Pharm. Corp., 642 F.2d 652, 662 (1st Cir.1981) (<HOLDING>). We follow the harmless error approach here in
holding that defendant was not harmed by submission of invalid fraud claim holding that evidence of nonpayment of salary and writing of bad checks did not result in submission of unpled theories of fraud liability where evidence supported pled fraud claim based on nonpayment of loan holding that the state must prove consent was voluntary not simply a submission to authority holding that governments weak interest in preserving grand jury secrecy did not warrant in camera submission where party seeking access to submission would learn of submission contents as soon as he was called as a grand jury witness holding that fraud claim requires proof that the defendant made a material representation that was false