In Skistimas v. Old World Owners Assn. (2005) 127 Cal.App.4th 948, the prevailing defendants were board members of a homeowners association (Association), and they had made section 998 settlement offers to Skistimas while the Association itself had not. (127 Cal.App.4th at pp. 950-951.) The issue was whether the prevailing defendants could recover their expert witness fees even though the Association's insurance carrier had paid those fees. (Id. at pp. 951-952.) The court drew a distinction between "personally" incurred fees (services that one is personally obligated to pay) and "actually" incurred fees (services performed on one's behalf that one is not necessarily personally obligated to pay). (Id. at p. 952, italics omitted.) It found that section 998 only strictly requires that expert witness costs have been "actually incurred" and concluded, "Whether the individual defendants paid the fees out of their own pockets or their insurer paid the fees on their behalf should not be determinative of their right to recover those fees." (127 Cal.App.4th at p. 952.)