Epstein Secrets

effrey Epstein SERVICE LIST Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, ■.

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

Page 32 of 33 SERVICE LIST Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L

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

ubmitted. /s/ &alai 9. Same Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L

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