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736-KAM Document 416 Entered on FLSD Docket 08/11/2017 Page 23 of 65 So far as appears in the available public materials, Senator Kyl's concern that the Justice Department's policy of conferring with victims about plea agreements before charges were filed would be a "dead letter" went unaddressed. Even today, the Justice
cted with the Justice Department's other statements on combatting sex abuse and trafficking. Attorney General Eric H. Holder Jr. Delivers Remarks at Justice Department Event Marking National Slavery and Human Trafficking Prevention Month (Jan. 29, 2015) http:/Avww.justice.gov/opa/speech/attomey-general-eric-h- holder-jr-
are irrelevant, and we really hope he does not prove the point that a man can commit heinous crimes against children and buy his way out of it. If the Department of Justice's recent commitment to the protection of our children from child molesters is to be more than rhetoric, then this is the time and the case where the
itable estoppel precludes challenging a document only where that party "must rely on the terms of the written agreement in asserting [her] claims." MS Dealer Service Corp. v. Franklin, 177 F.3d 942, 947 (11th Cir. 1999). Here, of course, the victims need not rely on the terms of the Government's non-prosecution agreem
sponsors to the Attorney General, regarding the DOJ's interpretation of the CVRA. D.E. 416 at 20-21. Petitioners contend that, "[i]t was because of the Justice Department's 6 EFTA00800013 Case 9:08-cv-80736-KAM Document 427 Entered on FLSD Docket 10/10/2017 Page 7 of 32 failure to follow the law — that is, its failu
s enforced, in accord with the terms of the statute, as enacted by Congress. In § 377/ (c)(1), Congress directed that, "[o]fficers and employees of the Department of Justice and other departments and agencies of the United States engaged in the detection, investigation, or prosecution of crime shall make their best effor
elements of equitable estoppel since they are not relying upon the terms of the written agreement in asserting their claims. D.E. 416 at 57, citing MS Dealer Service Corp. v. Franklin 177 F.3d 942, 947 (11'h Cir. 1999). They maintain that their claims in this litigation are not based on the NPA, but the CVRA. This arg
sponsors to the Attorney General, regarding the DOJ's interpretation of the CVRA. D.E. 416 at 20-21. Petitioners contend that, "[i]t was because of the Justice Department's 6 EFTA00799981 Case 9:08-cv-80736-KAM Document 425-1 Entered on FLSD Docket 10/06/2017 Page 8 of 33 failure to follow the law — that is, its fai
s enforced, in accord with the terms of the statute, as enacted by Congress. In § 377I (c)(1), Congress directed that, "[o]fficers and employees of the Department of Justice and other departments and agencies of the United States engaged in the detection, investigation, or prosecution of crime shall make their best effor
elements of equitable estoppel since they are not relying upon the terms of the written agreement in asserting their claims. D.E. 416 at 57, citing MS Dealer Service Corp. v. Franklin 177 F.3d 942, 947 (11th Cir. 1999). They maintain that their claims in this litigation are not based on the NPA, but the CVRA. This arg
Entities connected to both Department of Justice and MS Dealer Service Corp.

Jeffrey Epstein
PERSON
United States
LOCATIONLeon Black
PERSON
George W. Bush
PERSON
Kenneth Marra
PERSON
Bradley Edwards
PERSONMaria Farmer
PERSON
A. Marie Villafana
PERSON
Paul Cassell
PERSON
Oliver Stone
PERSONAce Greenberg
PERSON
Maine
LOCATION
S.J. Quinney College of Law
ORGANIZATION
the University of Utah
ORGANIZATION
Dexter Lee
PERSONFISTOS & LEHRMAN
ORGANIZATIONthe Eleventh Circuit
ORGANIZATION
Brady
PERSON
Tampa
LOCATIONKuyrkendall
PERSON