An appeal of a civil fraud verdict against a consultant in a case from Puerto Rico — similar charges were settled against former U.S. Sen. Birch Bayh, D-Ind., and Venable, where he is a partner, in a related case — was aired at the 1st U.S. Circuit Court of Appeals on Tuesday.

The oral argument in Victor Omar Portugues-Santana v. Rekomdiv International Inc. focused mainly on the standard of proof for “dolo,” a Puerto Rican claim akin to fraud.