Oo O DN OO FF WwW NY =|
NO RO PO PNP NM NO | S| S| HS SF S| S| S| S| S| non BP WO NO -|- ODO OO WDN OO OT BP WO NYO —
109
I think that would be, you know, subject to the debate which perhaps we are going to do now.
Q. No. Let's say you drew some inferences based on information you had; is that fair to say?
A. Sure.
Q. Okay. It's true, is it not, that you and your co-counsel, Mr. Edwards, had decided to seek the joinder of Miss Roberts and Jane Doe 4 as parties no later than the Summer of 2014?
A. Jane Doe 4, I think, give or take, yeah. I think Jane Doe -- well, that's -- there's a nomenclature issue. Let's refer to -- how do you want to refer to Virginia Roberts? Shall we just call her --
Q. I think we can call her Miss Roberts since the name is now known.
A. Right. Sure.
Q. And just clarifying, we can call Jane Doe 4. We won't use that name, Jane Doe 4.
A. Right. I think sometime in the Summer or the Fall the decision was made to -- to approach the U.S. Attorneys's Office to get their agreement to add her into the case. And they declined, which ultimately led to the filing on December 30th.
Q. Okay. And the basis for my question was, I
believe I saw in a pleading that you had represented to
ROUGH DRAFT ONLY
HOUSE_OVERSIGHT_021932