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UTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA JANE DOE 1 AND JANE DOE 2, Petitioners, vs. U
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
UTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA JANE DOE 1 AND JANE DOE 2, Petitioners, vs. U
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
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
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 Kenneth Marra and MS Dealer Service Corp.

Jeffrey Epstein
PERSON
Bradley Edwards
PERSON
Paul Cassell
PERSON
A. Marie Villafana
PERSON
United States
LOCATIONLeon Black
PERSON
George W. Bush
PERSON
Department of Justice
ORGANIZATIONMaria Farmer
PERSON
Dexter Lee
PERSON
the University of Utah
ORGANIZATION
S.J. Quinney College of Law
ORGANIZATIONFISTOS & LEHRMAN
ORGANIZATIONthe Eleventh Circuit
ORGANIZATIONKuyrkendall
PERSONAce Greenberg
PERSON
Oliver Stone
PERSONthe Fifteenth Judicial Circuit
ORGANIZATION
Tampa
LOCATIONJacqueline Perczek
PERSON