Epstein Secrets

tend that judicial estoppel 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 demons

those victims who have never reached out and asked to confer. Neither Jane Doe 1 nor Jane Doe 2 ever contacted AUSA Villafafia or FBI Special Agent Kuyrkendall regarding the case, despite being provided their phone numbers and addresses. D.E. 403-19,915. Since the Court's statutory interpretation of the te

tend that judicial estoppel 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 demons

those victims who have never reached out and asked to confer. Neither Jane Doe 1 nor Jane Doe 2 ever contacted AUSA Villafafia or FBI Special Agent Kuyrkendall regarding the case, despite being provided their phone numbers and addresses. D.E. 403-19,915. Since the Court's statutory interpretation of the te

would 25 EFTA00799849 Case 9:08-cv-80736-KAM Document 408 Entered on FLSD Docket 06/06/2017 Page 26 of 32 unfairly prejudice the opposing party. Tampa Bay Water v. HDR Engineering. Inc. 731 F.3d 1171, 1182 (11th Cir. 2013) citing Robinson v. Tyson Foods. Inc., 595 F.3d 1269, 1273 (11th Cir. 2010).

to obtain information from Jane Doe No. 2. Ex. B; Ex. S, 6-12. On April 24, 2007, Jane Doe No. 2 was interviewed by FBI Special Agents E. Nesbitt Kuyrkendall and Jason Richards and AUSA Marie Villafafia, in the presence of her attorney, James Eisenberg, Esq. Ex. C; Ex. R, I 5; Ex. S, q 12. Jane Doe No. 2

ld 25 EFTA00591486 Case 9:08-cv-80736-KAM Document 401-2 Entered on FLSD Docket 06/02/2017 Page 27 of 33 unfairly prejudice the opposing party. Tampa Bay Water v. HDR Engineering. Inc. 731 F.3d 1171, 1182 (11th Cir. 2013) citing Robinson v. Tyson Foods. Inc., 595 F.3d 1269, 1273 (11th Cir. 2010).

o obtain information from Jane Doe No. 2. Ex. B; Ex. S,11[6-12. On April 24, 2007, Jane Doe No. 2 was interviewed by FBI Special Agents E. Nesbitt Kuyrkendall and Jason Richards and AUSA Marie Villafafia, in the presence of her attorney, James Eisenberg, Esq. Ex. C; Ex. R, 15; Ex. S, ¶ 12. Jane Doe No. 2 d