Epstein Secrets

UTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA JANE DOE 1 AND JANE DOE 2, Petitioners, vs. U

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

UTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA JANE DOE 1 AND JANE DOE 2, Petitioners, vs. U

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

UTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA JANE DOE 1 AND JANE DOE 2, Petitioners, vs. U

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

es: The 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 formall

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

UTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA JANE DOE 1 AND JANE DOE 2, Petitioners, vs UN

F.2d 1324, 20 EFTA00299040 1325 (9th Cir. 1975). As this Court has recognized, "a contracting party is the paradigm of an indispensable party." HDR Engineering, Inc. v. R.C.T. Engineering, Inc., No. 08- 81040-CIV-ICAM, 2010 WL 2402908, *2 (S.D.Fla. June 15, 2010) (citation omitted). "Parties to a contract are ind

UTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 v. UNITED

al acceptance of the inconsistent later position would create the perception that either the earlier or later court was misled." Tampa Bay Water v. HDR Engineering, Inc., 731 F.3d 1171, 1182 (11th Cir. 2013)). In this case, even treating the filing of a civil court complaint as an earlier "proceeding," Epstein does n

UTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 v. UNITED

al acceptance of the inconsistent later position would create the perception that either the earlier or later court was misled." Tampa Bay Water v. HDR Engineering, Inc., 731 F.3d 1171, 1182 (11th Cir. 2013)). In this case, even treating the filing of a civil court complaint as an earlier "proceeding," Epstein does n