promissory estoppel doctrine in District of Columbia

1994See Bender v. Design Store Corp., 404 A.2d 194, 196 (D.C.1979) (citation omitted). “[Demonstration of a promise is a prerequisite to invocation of the doctrine of promissory estoppel.” United States Jaycees v. Bloomfield, 434 A.2d 1379, 1384 (D.C.1981) (citing Bender, supra, 404 A.2d at 195 ).

1994See Bender v. Design Store Corp., 404 A.2d 194, 196 (D.C.1979) (citation omitted). “[Demonstration of a promise is a prerequisite to invocation of the doctrine of promissory estoppel.” United States Jaycees v. Bloomfield, 434 A.2d 1379, 1384 (D.C.1981) (citing Bender, supra, 404 A.2d at 195 ).

1992B The question remains whether the prosecutor’s breach of his pretrial promise prejudiced appellant. 13 The government maintains, by an analogy to the contract doctrine of promissory estoppel, that even if the prosecutor’s statement could be considered a promise, appellant has failed to show any detrimental reliance on that promise prior to the government’s revocation or any “unavoidable injustice.” Bender v. Design Store Corporation, 404 A.2d *1024 194, 196 (D.C.1979); Moss v. Stockard, 580 A.2d 1011, 1034 (D.C.1990).

1992In general, to “hold a party liable under the doctrine of promissory estoppel there must be a promise which reasonably leads the promisee to rely on it to his [or her] detriment, with injustice otherwise not being avoidable.” Bender v. Design Store Corp., 404 A.2d 194, 196 (D.C.1979) (quotations and cites omitted); accord Moss v. Stockard, 580 A.2d 1011, 1034 (D.C.1990).

1979Our holdings have been, generally, that “[t]o hold a party liable under the doctrine of promissory estoppel ‘there must be a promise which reasonably leads the promisee to rely on it to his detriment, with injustice otherwise not being avoidable.’ ” Solway Decorating Co. v. Merando, Inc., supra at 362, quoting N. Litterio & Co. v. Glassman Construction Co., supra, 115 U.S.App.D.C. at 338 , 319 F.2d at 739 .

1979Our holdings have been, generally, that “[t]o hold a party liable under the doctrine of promissory estoppel ‘there must be a promise which reasonably leads the promisee to rely on it to his detriment, with injustice otherwise not being avoidable.’ ” Solway Decorating Co. v. Merando, Inc., supra at 362, quoting N. Litterio & Co. v. Glassman Construction Co., supra, 115 U.S.App.D.C. at 338 , 319 F.2d at 739 .

1995See Greater Newburyport, supra, 838 F.2d at 19 (“while disclosure might be of some indirect, casual or remote benefit to the defendant ... such elusive benefit is not weighty enough to overcome the policy against disclosure”) (quoting Mitchell v. Roma, 265 F.2d 633, 637 (3d Cir.1959)).

1995See Greater Newburyport, supra, 838 F.2d at 19 ("while disclosure might be of some indirect, casual or remote benefit to the defendant ... such elusive benefit is not weighty enough to overcome the policy against disclosure") (quoting Mitchell v. Roma, 265 F.2d 633, 637 (3d Cir.1959)).

1995See Greater Newburyport, supra, 838 F.2d at 19 (“while disclosure might be of some indirect, casual or remote benefit to the defendant ... such elusive benefit is not weighty enough to overcome the policy against disclosure”) (quoting Mitchell v. Roma, 265 F.2d 633, 637 (3d Cir.1959)).

1995See Greater Newburyport, supra, 838 F.2d at 19 ("while disclosure might be of some indirect, casual or remote benefit to the defendant ... such elusive benefit is not weighty enough to overcome the policy against disclosure") (quoting Mitchell v. Roma, 265 F.2d 633, 637 (3d Cir.1959)).

1995See Neuman v. Neuman, 377 A.2d 393, 398 (D.C.1977) ("rules of discovery are limited by Rule 26(b), which imposes a relevancy standard upon any matter that a party seeks to discover”) (citations and footnote omitted). .

1995See Neuman v. Neuman, 377 A.2d 393, 398 (D.C. 1977) ("rules of discovery are limited by Rule 26(b), which imposes a relevancy standard upon any matter that a party seeks to discover") (citations and footnote omitted). [11] In Arthur Treacher's, the court criticized this view on the basis that (1) it would be elementary to hone the questions to require greater and greater specificity regarding the matter discussed so as to avoid altogether the effectiveness of the privilege; and (2) the responses would be of little benefit to an opponent or the court if they were limited to the most general ter

1994See Bender v. Design Store Corp., 404 A.2d 194, 196 (D.C.1979) (citation omitted). “[Demonstration of a promise is a prerequisite to invocation of the doctrine of promissory estoppel.” United States Jaycees v. Bloomfield, 434 A.2d 1379, 1384 (D.C.1981) (citing Bender, supra, 404 A.2d at 195 ).

1990The judge concluded that the jury reasonably could have found the defendants “were es-topped from denying the existence of a contract for the 1981-82 season.” Thus, the judge did not enforce Moss’s promise to renew for that season as a formal contract, but rather on a theory of promissory estop-pel. “[T]o hold a party liable under the doctrine of promissory estoppel ‘there must be a promise which reasonably leads the promisee to rely on it to his detriment, with injustice otherwise not being avoidable.’ ” Solway Decorating Co. v. Merando, Inc., 240 A.2d 361, 362 (D.C.1968) (citation omitted);