Epstein Secrets

Y that on October 10, 2017, the foregoing was filed with the Clerk of the Court and served on counsel on the attached service list using CM/ECF. Is/Dexter A. Lee Dexter A. Lee Assistant United States Attorney 30 EFTA00800037 Case 9:08-cv-80736-KAM Document 427 Entered on FLSD Docket 10/10/2017 Page 31 of 3

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

FY that on October 6, 2017, the foregoing was filed with the Clerk of the Court and served on counsel on the attached service list using CM/ECF. Is/Dexter A. Lee Dexter A. Lee Assistant United States Attorney 30 EFTA00800005 Case 9:08-cv-80736-KAM Document 425-1 Entered on FLSD Docket 10/06/2017 Page 32 of

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

the following using the Court's CM/ECF system: Dexter Lee A. Marie Villafafia 500 S. Australian Ave., Sui

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