4
Shared Docs
4
Same-Page
4 / 4
Mentions
those victims who have never reached out and asked to confer. Neither Jane Doe 1 nor Jane Doe 2 ever contacted AUSA Villafafia or FBI Special Agent Kuyrkendall regarding the case, despite being provided their phone numbers and addresses. D.E. 403-19,915. Since the Court's statutory interpretation of the te
stoppel does not apply to them because the government has not established one of the elements of the three-part test examined in Tampa Bay Water v. HDR Engineering, Inc., 731 F.3d 1171 (11th Cir. 2013). D.E. 416 at 60. Specifically, petitioners contend the government has not demonstrated the second factor, that petit
o obtain information from Jane Doe No. 2. Ex. B; Ex. S,11 6-12. On April 24, 2007, Jane Doe No. 2 was interviewed by FBI Special Agents E. Nesbitt Kuyrkendall and Jason Richards and AUSA Marie in the presence of her attorney, James Eisenberg, Esq. Ex. C; Ex. R, 5; Ex. S, ¶ 12. Jane Doe No. 2 described he
he earlier or later court was misled; and (3) whether the inconsistent later position would unfairly prejudice the opposing party. Tampa Bay Water,. HDR Engineering, Inc., 731 F.3d 25 EFTA00211742 1171, 1182 (11th Cir. 2013) citing Robinson I. Tyson Foods. Inc., 595 F.3d 1269, 1273 (I I th Cir. 2010). In their st
those victims who have never reached out and asked to confer. Neither Jane Doe 1 nor Jane Doe 2 ever contacted AUSA Villafafia or FBI Special Agent Kuyrkendall regarding the case, despite being provided their phone numbers and addresses. D.E. 403-19,915. Since the Court's statutory interpretation of the te
stoppel does not apply to them because the government has not established one of the elements of the three-part test examined in Tampa Bay Water v. HDR Engineering, Inc., 731 F.3d 1171 (11th Cir. 2013). D.E. 416 at 60. Specifically, petitioners contend the government has not demonstrated the second factor, that petit
d issues of fact on some aspects of this important meeting, it is interesting to see the limitations in the declaration. Here is what Special Agent Kuyrkendall states: In October 2007, my co-case agent and I met with Jane Doe #1 at a Publix grocery store in Palm Beach Gardens. We were meeting with Jane Doe
position would create the perception that either the earlier or later court was misled." DE 401-2 at 25 (emphasis added) (citing Tampa Bay Water v. HDR Engineering, Inc., 731 F.3d 1171, 1182 (11th Cir. 2013)). In this case, even treating the state court proceedings as the "earlier" proceedings, the Government does n
Entities connected to both Kuyrkendall and HDR Engineering, Inc.

A. Marie Villafana
PERSON
Jeffrey Epstein
PERSON
Kenneth Marra
PERSON
Alexander Acosta
PERSON
Jeffrey Sloman
PERSON
Dexter Lee
PERSON
Bradley Edwards
PERSONJane Doe
PERSON
Department of Justice
ORGANIZATION
United States
LOCATION
George W. Bush
PERSONLeon Black
PERSONMaria Farmer
PERSON
Paul Cassell
PERSON
the University of Utah
ORGANIZATIONFISTOS & LEHRMAN
ORGANIZATIONthe Eleventh Circuit
ORGANIZATIONJames Eisenberg
PERSON
Harvey Weinstein
PERSONGarcia
PERSON