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EFTA00811276
o an express contract are bound by an implied duty of good faith, but breach of that duty is merely a breach of the underlying contract." Harris v. Provident Life & Accident Ins. Co., 310 F.3d 73, 80 (2d Cir.2002). In other words, "a breach of the implied covenant is not a separate cause of action." Payday Advance Plus, Inc. v.
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