Whether the Second Circuit Court of Appeals erred in its holding regarding damages

ISSUES PRESENTED FOR REVIEW 1. Whether the Second Circuit Court of Appeals in holding that the damages presented in the summary judgment record were not reasonably certain, by failing to consider the general and special damages presented by 1st Fidelity and S&A, and by failing to allow those damages to be presented to a trier of fact, and, thus, granting summary judgment? 2. Whether the Second Circuit Court of Appeals erred by failing to apply the tolling doctrine of continuing violation when examining the statute of limitations defense raised by the Respondents, and by upholding the trial court’s granting of summary judgment for the Respondents when there exists issues of genuine material fact regarding whether Petitioner’s damages were caused by the continuing and ongoing breaches of the Parties Agreements by the Respondents, or were solely the result of continuing harm from a single breach? 3. Whether the Second Circuit Court of Appeals erred in ruling that all future breaches by the Respondents regarding more than three thousand five hundred (3,500) mortgage loans which were purchased by Petitioners from Respondents: where Respondents accepted payments from 1 borrowers and insurance companies for loans which had been sold to Petitioner; Loans that were subsequently either discharged/forgiven by Respondent without the Petitioners’ permission or knowledge; where the Respondents re-assigned to themselves mortgages purchased by the Petitioners; or where Respondents took action(s) which interfered with Petitioners’ ability to enforce/collect upon their mortgages purchased from the Respondent; are time barred because they relate back to the original breach rather than the Respondents’ actions subsequent to the accrual date determined by the trial court, and the Respondents’ ongoing breaches demonstrated below? i