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