In Demarest v. Ocwen Loan Servicing, LLC, 2012 WL 4320115 (9th Cir. 2012), the Court of Appeals for the Ninth Circuit held, in a brief unpublished opinion related to a pro per plaintiff, that “The district court did not abuse its discretion by applying judicial estoppel to Demarest’s TILA damages claim because she attempted to pursue the claim without having disclosed it during her bankruptcy proceedings. See Hamilton, 270 F.3d at 784 (“Judicial estoppel will be imposed when the debtor has knowledge of enough facts to know that a potential cause of action exists during the pendency of the bankruptcy, but fails to amend his schedules or disclosure statements to identify the cause of action as a contingent asset.””