The court found that those facts were sufficient to raise the issue of estoppel in this action.See id. at 3-4 (citing Garcia v. Peter Carlton Enters., 717 F.Supp. 1321, 1326 (N.D. Ill. 1989) ("Estoppel principles ordinarily apply in cases in which a defendant knowingly allows or actually misleads a plaintiff into thinking it has sued the proper entity and the defendant appears ready to defend itself, but after the statute of limitations runs the defendant suddenly claims it is not the party to be sued."); Conradi v. Boone, 316 F.Supp. 918, 921 (S.D. Iowa 1970) (finding that plaintiffs' claim of equitable estoppel presented genuine issues as to certain material facts and that a trier of fact could conclude that defendants were estopped from asserting the bar of the statute of limitations based on conduct of one of defendants' insurers)). On March 16, 2005, Plaintiff filed her memorandum regarding estoppel.

The Iowa courts have generally adopted the "most significant relationship" rule in the choice of law area: The Court is "to apply to any issue in litigation the law of the [jurisdiction] which has the most significant relationship with the parties and the principal interest in the issue. . . ." Berghammer v. Smith, 185 N.W.2d 226, 230 (Iowa 1971); cf. Fuerste v. Bemis, 156 N.W.2d 831 (Iowa 1968); Bankord v. DeRoch, supra; Conradi v. Boone, 316 F. Supp. 918 (S.D. Iowa 1970); Restatement (Second) of Conflicts (1971). This rule does, however, have its limitations, as will be seen.

We are not certain that the substantive law of the Cayman Islands would govern this dispute entirely. In conflict-of-laws questions, Iowa has adopted the "most significant relationship" approach of the Restatement (Second) of Conflict of Laws. Conradi v. Boone, 316 F. Supp. 918, 920 (S.D.Iowa 1970); Cole v. State Automobile Casualty Underwriters, 296 N.W.2d 779, 781 (Iowa 1980); Zeman v. Canton State Bank, 211 N.W.2d at 348-49. Under this approach (we note without deciding the issue) it is probable that the substantive law of the Cayman Islands would govern the negligence count.

Glus, supra; Scarborough, supra. See generally, Conradi v. Boone, 316 F. Supp. 918 (S.D.Iowa 1970). It follows that there cannot be estoppel by inference.

Equitable estoppel is a recognized defense to the application of a time-bar statute. DeWall v. Prentice, 224 N.W.2d 428, 430 (Iowa 1974); L W Construction Co. v. Kinser, 251 Iowa 56, 66, 99 N.W.2d 276, 282 (1959); Conradi v. Boone, 316 F. Supp. 918, 920 (S.D.Iowa 1970). In its opinion in the Beecks' litigation the federal district court considered the possibility of a fraud case against the true manufacturer and then stated: