Where the means of a fraudulent scheme are not separate elements requiring unanimity from the jury for conviction, the lower court order was affirmed.The 7th U.S. Circuit Court of Appeals affirmed a decision by U.S. District Judge Manish S. Shah.Between 2002 and 2008, Edward Boliaux operated EMC Automotive, a used car dealership in southwest suburban Joliet.Boliaux borrowed money from three lenders, using inventory as security. The loans were secured by the cars’ certificates of title, a device called floorplanning …