Epstein Secrets

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA/JOHNSON JANE DOE #1 AND JANE DOE #2, Petitioners, vs. UNITED STATES, Respondent. UNITED STATES' SEALED REPLY IN SUPPORT OF ITS MOTION TO DISMISS FOR L

ellation of conveyance was precluded by delay in seeking that remedy and affirmative action evincing election to allow agreement to stand); Blincol Green Tree Servicing LLC, 400 F.3d 1308, 1312 (11th Cir. 2005) ("Equitable estoppel precludes a party from claiming the benefits of a contract while simultaneously attempti

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA/JOHNSON JANE DOE #1 AND JANE DOE #2, Petitioners, vs. UNITED STATES, Respondent. UNITED STATES' SEALED REPLY IN SUPPORT OF ITS MOTION TO DISMISS FOR L

ellation of conveyance was precluded by delay in seeking that remedy and affirmative action evincing election to allow agreement to stand); Blincol Green Tree Servicing LLC, 400 F.3d 1308, 1312 (11th Cir. 2005) ("Equitable estoppel precludes a party from claiming the benefits of a contract while simultaneously attempti

he most recent court decision to carefully review the Justice Department's position is Jane Does #1 and #2 v. United States, No. 08-80736-CIV- MARRA/JOHNSON (S.D. Fla. Sept. 26, 2011). In that case, the court flatly rejected the Department's claim that rights attach only after charges are formally filed

ged Care litigation, 285 F.3d 971, 976 (11'" Cir. 200) (construing provision in arbitration clause entered into by patient with hospital); Bunco v. Green Tree Servicing LLC, 400 F.3d 1308, 1312 (11'h Cir. 2005) (construing provision in 10 The Government raised another estoppel argument earlier, but not the particular cl

ument 205-6 Entered on FLED Docket 07/05/2013 Page 2 of 101 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA/JOHNSON JANE DOE #1 AND JANE DOE #2, Petitioners, vs. UNITED STATES, Respondent. UNITED STATES' SEALED REPLY IN SUPPORT OF ITS MOTION TO DISMISS FOR L

lation of conveyance was precluded by delay in seeking that remedy and affirmative action evincing election to allow agreement to stand); Blinco v. Green Tree Servicing LLC, 400 F.3d 1308, 1312 (11th Cir. 2005) ("Equitable estoppel precludes a party from claiming the benefits of a contract while simultaneously attempti

ument 205-6 Entered on FLED Docket 07/05/2013 Page 2 of 101 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA/JOHNSON JANE DOE #1 AND JANE DOE #2, Petitioners, vs. UNITED STATES, Respondent. UNITED STATES' SEALED REPLY IN SUPPORT OF ITS MOTION TO DISMISS FOR L

lation of conveyance was precluded by delay in seeking that remedy and affirmative action evincing election to allow agreement to stand); Blinco v. Green Tree Servicing LLC, 400 F.3d 1308, 1312 (11th Cir. 2005) ("Equitable estoppel precludes a party from claiming the benefits of a contract while simultaneously attempti

ument 205-6 Entered on FLSD Docket 07/05/2013 Page 2 of 101 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA/JOHNSON JANE DOE #1 AND JANE DOE #2, Petitioners, vs. UNITED STATES, Respondent. UNITED STATES' SEALED REPLY IN SUPPORT OF ITS MOTION TO DISMISS FOR L

lation of conveyance was precluded by delay in seeking that remedy and affirmative action evincing election to allow agreement to stand); Blinco v. Green Tree Servicing LLC, 400 F.3d 1308, 1312 (11th Cir. 2005) ("Equitable estoppel precludes a party from claiming the benefits of a contract while simultaneously attempti

Appendix F EFTA00208822 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA/JOHNSON JANE DOE #1 AND JANE DOE #2, Petitioners, vs. UNITED STATES, Respondent. UNITED STATES' SEALED REPLY IN SUPPORT OF ITS MOTION TO DISMISS FOR L

lation of conveyance was precluded by delay in seeking that remedy and affirmative action evincing election to allow agreement to stand); Blinco v. Green Tree Servicing LLC, 400 F.3d 1308, 1312 (11th Cir. 2005) ("Equitable estoppel precludes a party from claiming the benefits of a contract while simultaneously attempti