109 1 I think that would be, you know, subject to the debate 2 which perhaps we are going to do now. 3 Q. No. Let's say you drew some inferences based 4 on information you had; is that fair to say? 5 A. Sure. 6 Q. Okay. It's true, is it not, that you and 7 your co-counsel, Mr. Edwards, had decided to seek the 8 joinder of Miss Roberts and Jane Doe 4 as parties no 9 later than the Summer of 2014? 10 A. Jane Doe 4, I think, give or take, yeah. I 11 think Jane Doe -- well, that's -- there's a nomenclature 12 issue. Let's refer to -- how do you want to refer to 13 Virginia Roberts? Shall we just call her -- 14 Q. I think we can call her Miss Roberts since 15 the name is now known. 16 A. Right. Sure. 17 Q. And just clarifying, we can call Jane Doe 4. 18 We won't use that name, Jane Doe 4. 19 A. Right. I think sometime in the Summer or the 20 Fall the decision was made to -- to approach the U.S. 21 Attorneys's Office to get their agreement to add her 22 into the case. And they declined, which ultimately led 23 to the filing on December 30th. 24 Q. Okay. And the basis for my question was, I 25 believe I saw in a pleading that you had represented to ROUGH DRAFT ONLY HOUSE_OVERSIGHT_021932