How have the courts applied the principles of judicial estoppel in the context of a lender liability suit?

Hamilton v. Greenwich Investors (2011) 195 Cal.App.4th 1602, which applied these principles in the context of a lender liability suit, held that the trial court properly sustained a demurrer without leave to amend based on judicial estoppel because the debtor had failed to disclose a claim against one of his principal creditors despite the bankruptcy schedules expressly asking for counterclaims and rights to setoff claims. (Id. at pp. 1609, 1613.) Because the events underlying the claim occurred before the debtor filed for bankruptcy, the debtor "must have known of the facts allegedly justifying the claim." (Id. at p. 1614.)