context: Indeed, courts in this Circuit have found it appropriate to apply the doctrine to bar claims brought by litigants who had previously acted in bad faith in concealing those claims during prior bankruptcy proceedings.
citation_a.signal: but see
citation_a.identifier: 81 F.3d 362, 362-65
citation_a.parenthetical: rejecting application of judicial estoppel based on lack of evidence of plaintiffs bad faith in failing to disclose contingent claims in pri- or bankruptcy proceeding
citation_a.sentence: But see Ryan, 81 F.3d at 362-65 (rejecting application of judicial estoppel based on lack of evidence of plaintiffs bad faith in failing to disclose contingent claims in pri- or bankruptcy proceeding).
citation_b.signal: see
citation_b.identifier: 217 B.R. 739, 754-56
citation_b.parenthetical: barring plaintiffs civil rights claim against defendant because plaintiff represented the contingent claim to the bankruptcy court as having little value and later filed a claim for $750,000, an amount that would have satisfied all of plaintiffs outstanding debts
citation_b.sentence: See, e.g., Krystal, 337 F.3d at 319-25 (applying judicial estoppel to bar debtor plaintiffs claim against defendant creditor for violation of the automatic stay imposed by the Bankruptcy Code because plaintiff knew about the claim during the prior bankruptcy proceeding and had a motive to conceal it in the face of an affirmative duty to disclose); Oneida Motor Freight, Inc. v. United Jersey Bank, 848 F.2d 414, 419-420 (3d Cir.1988) (invoking judicial es-toppel against debtor plaintiff to bar claims for breach of contract, breach of the duty of good faith, and fraudulent misrepresentation against defendant creditor because plaintiff failed to disclose those claims in bankruptcy proceedings despite citing defendant’s improper activities as the catalyst for its bankruptcy filing); In re Okan’s Foods, Inc., 217 B.R. 739, 754-56 (Bankr.E.D.Pa.1998) (barring plaintiffs civil rights claim against defendant because plaintiff represented the contingent claim to the bankruptcy court as having little value and later filed a claim for $750,000, an amount that would have satisfied all of plaintiffs outstanding debts).