The following excerpt is from Friedman v. Self Help Cmty. Servs., Inc., 15-1042-cv (2nd Cir. 2016):
4. Plaintiff did not challenge in the district court and does not challenge on appeal the incorporation by reference of his medical records into the complaint. Nor has he challenged the fact (as opposed to the accuracy) of the diagnoses contained therein. Accordingly, any objection to the consideration of those documents is deemed waived. See Norton v. Sam's Club, 145 F.3d 114, 117 (2d Cir. 1998) ("Issues not sufficiently argued in the briefs are considered waived and normally will not be addressed on appeal.").
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