Express, 849 F.2d 464, 467-68 (10th Cir. 1988)); Khan v. Parsons Global Servs., Ltd., 521 F.3d 421, 425 (D.C. Cir. 2008) (quoting Nat'l Found, for Cancer Research v. A.G. Edwards & Sons, 821 F.2d 772, 774-75 (D.C. Cir. 1987)); In re Crysen/Montenay Energy Co., 226 F.3d 160, 163 (2d Cir. 2000); PPG Indus., Inc. v. Webster Auto Parts, Inc., 128 F.3d 103, 107 (2d Cir. 1997); Cabinetree of Wis., Inc. v. Kraftmaid Cabinetry, Inc., 50 F.3d 388, 391 (7th Cir. 1995). 30 . Compare Sovak, 280 F.3d at 1270 (noting in Ninth Circuit party has “heavy burden” in showing prejudice (quoting Britton, 916 F.2d at 1412)), with In re Tyco Int’l Ltd. Sec. Litig., 422 F.3d 41, 44-45 (1st Cir. 2005) (noting First Circuit requires party to demonstrate "modi 2007 WL 927222, at *5 (Ohio App. Mar. 29, 2007) (<HOLDING>); G.T. Leach Builders, LLC, 2012 WL 506568, at
holding that consideration for guaranty of loan previously made was that guarantors friend the bank manager who issued the loan would not lose his job for making a bad loan holding that debtcollection action was closely related to fraud in origination of the loan holding that a plaintiff cannot avoid the securities fraud exception by pleading mail fraud or wire fraud if the conduct giving rise to those offenses also amounts to securities fraud holding that where parties to an oral loan agreed that the loan would be repaid on demand the statute of limitations did not begin to run until the date plaintiff demanded repayment of the loan holding that fraudulent loan transaction exposed financial institutions to risk of loss even though loan was secured