MINER, Circuit Judge:
Third-party plaintiff-appellant Federal Insurance Co. ("Federal") appeals from a portion of a judgment entered after a jury trial in the United States District Court for the Southern District of New York (Sand, J.) in favor of third-party defendant-appellee Flota Mercante Grancolombiana, S.A. ("Flota"). On this appeal, Federal challenges the entry of a directed verdict on Federal's "estoppel" theories of liability. Finding no
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