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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
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
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
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
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
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
Entities connected to both Kuyrkendall and MS Dealer Service Corp.

A. Marie Villafana
PERSON
Jeffrey Epstein
PERSON
Kenneth Marra
PERSON
Dexter Lee
PERSON
Bradley Edwards
PERSON
United States
LOCATION
Department of Justice
ORGANIZATION
George W. Bush
PERSONLeon Black
PERSONMaria Farmer
PERSON
Paul Cassell
PERSONFISTOS & LEHRMAN
ORGANIZATION
the University of Utah
ORGANIZATION
S.J. Quinney College of Law
ORGANIZATIONthe Eleventh Circuit
ORGANIZATION
Brady
PERSONJacqueline Perczek
PERSONAnn Marie C. Villafafia
PERSONAce Greenberg
PERSON
Maine
LOCATION