mate cause analyses. Id. at 350, citing 27 EFTA00078861 Case 9:08-cv-80736-KAM Document 62 Entered on FLSD Docket 04/08/2011 Page 28 of 54 In Re Rendon Galvis, 564 F.3d 170, 175 (2nd Cir. 2009). As applied to McNulty, the issue was whether he was directly and proximately harmed by criminal conduct in the c

A Case No. 08-80736-CIV-MARRA/JOHNSON EFTA00208063 Case 9:08-cv-80736-KAM Document 57-1 Entered on FLSD Docket 04/07/2011 Page 28 of 54 In Re Rendon Galvis, 564 F.3d 170, 175 (2n° Cir. 2009). As applied to McNulty, the issue was whether he was directly and proximately harmed by criminal conduct in the c

ment that a victim be "directly and proximately harmed" encompassed the traditional "but for" and proximate cause analyses. Id. at 350, citing In Re Rendon Galvis , 564 F.3d 170, 175 (2 ' Cir. 2009). As applied to McNulty, the issue was whether he was directly and proximately harmed by criminal conduct in the

, citing 27 EFTA00230092 ff ell.;;;;;:t; --- ------- 1 Case 9:O8-cv-80736-KAM Document 62 Entered on FLSD Docket 04/08/2011 Page 28 of 54 In Re Rendon Galvis, 564 F.3d 170, 175 (2gd Cir. 2009). As applied to McNulty, the issue was whether he was directly and proximately harmed by criminal conduct in the c

ate cause analyses. Id. at 350, citing 27 EFTA00177077 Case 9:08-cv-80736-KAM Document 62 Entered on FLSD Docket 04/08/2011 Page 28 of 54 In Re Rendon Galvis, 564 F.3d 170, 175 (20° Cir. 2009). As applied to McNulty, the issue was whether he was directly and proximately harmed by criminal conduct in the