Under the doctrine of judicial estoppel, should the lower courts have upheld the sanctity of the oath and estopped USC and Gibson Dunn from arguing inconsistent positions that spanned a decade-and-a-half?

QUESTIONS PRESENTED Dr. Isaacs respectfully petitions the United States Supreme Court to address the following questions presented and grant a writ of certiorari. 1. Under the doctrine of judicial estoppel, should the lower courts have upheld the sanctity of the oath and estopped USC and Gibson Dunn from arguing inconsistent positions that spanned a decade-and-a-half? 2. Did USC and Gibson Dunn present knowingly false statements to the Ninth Circuit, when asked multiple times whether the intent of the Isaacs-USC 2008 settlement agreement was to invalidate the Isaacs-USC 2007 settlement, or did Robin Dal Soglio falsely represent to the District Court that the 2008 settlement “had no effect” on the 2007 settlement agreement? 3. Dr. Isaacs’ medical license (see 2018 cert petition) was revoked for his reliance upon Dal Soglio’s above representation. Should a physician be effectively barred from medical practice for life, because he relied upon one of two contradictory positions taken by USC counsel over a span of fourteen years? 4. Does FRCP 41(d) allow for award of attorneys’ fees, or is it limited to costs, per the plain language of the Rule? li QUESTIONS PRESENTED — Continued 5. Per dissenting Judge Ikuto, is “the [majority] interpretation unreasonable” that a settlement agreement was written with intent to be unenforceable?! Petitioner Dr. Jeffrey Isaacs has spent nearly his entire adult life in federal court, seeking to enforce a settlement agreement with University of Southern California’s Keck School of Medicine that would allow him to practice medicine. This Petition marks his fifth attempt seeking certiorari, concerning an unfortunate series of events that continue to malignantly escalate. In 2005, Petitioner enrolled at University of Southern California’s Keck School of Medicine. In litigation that ensued in the California Central District, then medical student Jeffrey Isaacs raised three specific whistleblower concerns: 1) USC engaged in bribery and pay-for-play admissions, 2) a Dean treated him 1 “The majority today affirms the district court on the ground that the language in the 2008 settlement agreement entitles USC to legal fees for any lawsuit brought by Isaacs that ‘refer[s] to, or incorporatles]’ or is ‘based on any events, acts or omissions through and including the date [of the agreement].’ Apparently, the majority interprets this language as precluding Isaacs from bringing a lawsuit to enforce either the 2007 or 2008 settlement agreement, because such a lawsuit would necessarily refer to an act that occurred before (or on the date of ) the 2008 settlement agreement — namely, the execution of the settlement agreements themselves. Such an interpretation is unreasonable. The parties clearly did not intend that by entering into the 2008 settlement agreement, Isaacs would be precluded from enforcing it ... This conclusion makes the settlement agreements unenforceable.” ili QUESTIONS PRESENTED — Continued suspiciously “inappropriately,” and 3) USC coerced him into an illegal settlement agreement. Generally, a decade and a half later no controversy exists that USC engaged in all of these improper practices. The FBI Operation Varsity Blues resulted in RICO guilty verdicts for USC admissions practices. In 2010, a Keck Medical School Dean was removed from his post after being caught in a “drug-fueled relationship” with a teenager. To settle that case, it was revealed just last week that USC coerced an illegal settlement agreement that stipulated for the destruction of evidence pertaining to an ongoing criminal investigation.” Specifically, Petitioner’s own claims were never proven true or false, because in 2007 Isaacs reached a settlement with USC whereby he dropped claims against individual deans. In consideration thereof, Isaacs’ contested disciplinary record was sealed and he was granted factual innocence as to the retaliatory allegations that lead to his departure from USC. Already enrolled in another medical sch