In Haley v. Dow Lewis Motors, Inc., 72 Cal. App. 4th 497 (1999), a California appellate court explained the doctrine of judicial estoppel: Judicial estoppel, sometimes called the "doctrine against the assertion of inconsistent positions," is a judge-made doctrine that seeks to prevent a litigant from asserting a position inconsistent with one that she has previously asserted in the same or in a previous proceeding. .. It is designed to prevent litigants from 'playing "fast and loose with the courts." .... Asserting inconsistent positions does not trigger application of judicial estoppel unless "intentional self-contradiction is . . . used as a means of obtaining unfair advantage." Thus, the doctrine of judicial estoppel does not apply "when the prior position was taken because of a good faith mistake rather than as part of a scheme to mislead the court." An inconsistent argument sufficient to invoke judicial estoppel must be attributable to intentional wrongdoing. (72 Cal. App. 4th 497 at 509-10.)