degree, but failed to present any evidence of her specialized knowledge with respect to fitness assessments. Accordingly, the district court did not abuse its discretion in excluding Downing’s memorandum. And with no other evidence that the results of Downing’s fitness assessments were inac curate, summary judgment in favor of LTF on this breach-of-contract claim was appropriate. 7. Fraud Downing alleged in support of her fraud claim that LTF “purposefully provided inaccurate results and advice” with respect to the fitness assessments. Like her breach-of-contract claim, Downing’s fraud claim fails because she provides no admissible evidence that LTF’s results and advice were false. See Zaremba Equip., Inc. v. Horco Nat’l Ins. Co., 280 Mich.App. 16, 761 N.W.2d 151, 165 (2008) (<HOLDING>). 8. Freedom of Association and Due Process In
holding that a false light claim requires pleading and proof of special damages holding that even if the defendant believed that the property was worth what the victim of the fraud paid for it the fact that the seller made a false representation to inflate the purchase price constituted intent to defraud under  1343 holding that the offense requires that the return be false as to a material matter holding that a false representation of a material matter of fact is a necessary element of a rescission claim holding that fraud claim requires proof that the defendant made a material representation that was false