pursuant to HAMP, reasoning that TPPs lacked definite terms or lacked consideration. See, e.g., Senter v. JPMorgan Chase Bank, N.A., 810 F.Supp.2d 1339, 1348-49 (S.D. Fla. 2011). Others reasoned that state breach-of-contract claims fail to state a cause of action independently of HAMP. See, e.g., Bourdelais v. J.P. Morgan Chase, No. 3:10-CV-670-HEH, 2011 WL 1306311, at *4 (E.D. Va. Apr. 1, 2011). Later opinions have tended to take a different approach. See, e.g., Bosque v. Wells Fargo Bank, N.A., 762 F.Supp.2d 342, 351 (D. Mass. 2011) ("[D]efendant contends that because the TPPs originated out of the HAMP program, plaintiffs cannot vindicate any rights that relate to HAMP, That argument is plainly without merit.”); Nash v. Green Tree Servicing, LLC, 943 F.Supp.2d 640, 647 (2013) (<HOLDING>). As mentioned, we held in the prior appeal in
holding that a breach of contract claim against one defendant related back to interference with contract claim against that defendant and breach of contract claim against second defendant because it was based on same set of operative facts recognizing that the elements of a claim for breach of contract are 1 existence of a valid contract and 2 breach of the terms of that contract holding that the facts asserted that a breach of contract may have occurred under virginia law based on a tpp agreement holding that a cause of action for breach of contract accrues at the time of the breach holding immaterial breach did not constitute breach of contract