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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
MARY JUDGMENT Respondent United States of America, by and through its undersigned counsel, files its Reply to Petitioners' Response to Government's Cross-Motion for Summary Judgment, and states: I. JANE DOE 2 CLEARLY EXPRESSED HER DESIRE NOT TO BE TREATED AS A VICTIM OF EPSTEIN During the Government's investigation into Jeff
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
ATE OF SERVICE I HEREBY CERTIFY that on June 2, 2017, the foregoing Response and Opposition to Petitioners' Motion for Partial Summary Judgment and Cross-Motion for Summary Judgment was filed with the Clerk of the Court and served on counsel on the attached service list using CM/ECF. is/Dexter . Lee 31 EFTA00211748 SERVICE
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
MARY JUDGMENT Respondent United States of America, by and through its undersigned counsel, files its Reply to Petitioners' Response to Government's Cross-Motion for Summary Judgment, and states: I. JANE DOE 2 CLEARLY EXPRESSED HER DESIRE NOT TO BE TREATED AS A VICTIM OF EPSTEIN During the Government's investigation into Jeff
Entities connected to both HDR Engineering, Inc. and Cross-Motion for Summary Judgment

United States
LOCATION
Kenneth Marra
PERSON
Jeffrey Epstein
PERSON
Department of Justice
ORGANIZATION
Bradley Edwards
PERSON
Paul Cassell
PERSONJacqueline Perczek
PERSONLeon Black
PERSONMaria Farmer
PERSON
Dexter Lee
PERSON
George W. Bush
PERSONFISTOS & LEHRMAN
ORGANIZATIONKuyrkendall
PERSON
the University of Utah
ORGANIZATIONthe Eleventh Circuit
ORGANIZATIONBENJAMIN G. GREENBERG
PERSON
A. Marie Villafana
PERSON
Alexander Acosta
PERSON
S.J. Quinney College of Law
ORGANIZATIONAce Greenberg
PERSON