39 1 MR. SIMPSON: I'm not going to ask any 2 details at all. 3 BY MR. SIMPSON: 4 Q. I'm simply going to ask: Is it in writing, 5 yes or no? As of December 30th, 2014, was there a 6 written common interest agreement, yes or no? 7 MR. SCAROLA: Those are two different 8 questions and I think the record needs to be 9 clear as to which one you're asking. 10 MR. SIMPSON: All right. Let me ask this 11 question. 12 BY MR. SIMPSON: 13 Q. As of December 30th, 2014, was there any 14 common interest agreement that was in writing? 15 A. I'm not certain what date a written agreement 16 was executed on these subjects. 17 Q. At some point, was a written agreement 18 executed? 19 A. Yes. 20 Q. And who were the parties to the written 21 agreement? 22 A. Well, there have been addenda to the 23 agreement, if I recall correctly, but sitting here 24 today, the parties to the agreement include Virginia 25 Roberts, and her -- well, attorneys representing -- I ROUGH DRAFT ONLY HOUSE_OVERSIGHT_021862