1

2

3

DEPOSITION OF ROSEMARY STEWART

VOL. II

267

there at that time, correct?

• Yes.

Q. And his title, was he general counsel?

A.

General counsel to the Federal Home

Loan Bank of San Francisco.

There was one other member of the

Executive Committee as a six-man committee, and

that was Frank Hotz.

MR. GALLAGHER : Mark that next in order,

please.

(Deposition Exhibit No. 51 was marked for

identification.)

MS.

Q. (BY MR. GALLAGHER) I will hand you,

Stewart, what the reporter has marked as

Exhibit 51, and ask you to take a look at those

and see if they appear to be a complete and
accurate set of the Enforcement Review Committee
minutes?

Yes, they appear to be.

MR. MURPHY: Just for clarification, I assume your question was made with respect to Lincoln?

MR. GALLAGHER: Oh, I'm sorry. Yes.

Q. (BY MR. GALLAGHER)

The Enforcement

Review Committee had other things to do besides

STICKLEY & SCHUTZMAN, INC.

DEPOSITION OF ROSEMARY STEWART VOL. II

268

1

Lincoln, correct?

▲. Yes. And we prepared these particular minutes only with regard to Lincoln discussions. Throughout this same period of time, there are other minutes related to other topics.

Q. What percentage of your time in 1988,
and by your time I mean Enforcement Review
Committee, what percentage of your time in 1988
would you estimate was attributed to Lincoln
versus other activities?

MR. MURPHY: By ERC, by Enforcement Review
Committee, do you mean time spent in the

committee deliberations or in the meetings?

Q. (BY MR. GALLAGHER) The Enforcement Review Committee did things other than just meet, right?

items.

A. Yes. We acted on notational voting

Q. I'm talking about all of your effort, all of the Enforcement Review Committee's efforts during '88, whatever they might have been, whether in or out of meetings, I would like to know, if you can estimate for me, what percentage

of that time was devoted to Lincoln matters?

MR. MURPHY: I am going to object. І веал

STICKLEY & SCHUTZMAN, INC.

DEPOSITION OF ROSEMARY STEWART VOL. II

1

the fact that the people on these committees had

a lot of other duties besides the Enforcement
Review Committee, and if you are asking what
percentage of their time they spent on Lincoln

Batters, seens to me impossible for Ms. Stewart
to know, and the percentage would vary.

If what you are saying is how much of the total ERC's meeting time was spent on Lincoln matters, I can understand that question, and I think Ms. Stewart might be able to understand it. Q. (BY MR. GALLAGHER) Well, I will start with that one.

Of all the meetings you had, what
percentage of them were devoted to Lincoln?
A. Well, between January '88 and May 88,

I would say that half of the committee's time was
spent working on Lincoln and half on other

matters.

Q. Now does your answer go only to meeting time or does it go to overall time?

17

18

19

20

21

22

23

24

25

STICKLEY & SCHUTZMAN, INC.

Q. Are you able to give me any estimate as to overall ERC efforts and what percentage of those were devoted to Lincoln as opposed to other Batters?

269

Objection.

I'm going to object for the

same reason I said before; I mean

Q. (BY MR. GALLAGHER) I just don't know

if you can do it or not.

MR. MURPHY: I mean, your latter question just starts talking about individuals on the committee. It's not like the committee is always acting. These people have a lot of different duties, one of which is being on the committee, Jin, if she doesn't know, I presume she is going to tell me that.

MR. GALLAGHER : Right.

She may know. I don't know.

THE WITNESS: I don't believe I can answer that. Between January and May, this took a considerable amount of our meeting time. I mean

12

13

14

15

16

17

we considered this to be a big, significant

18

Batter.

19

Throughout that time, I continued to

ask you this, Ms.

give notational voting itens to the members.
They do that in their own time, so I'm not sure
how much time they would have spent on those.

Q. (BY MR. GALLAGHER) All right. Let me
Stewart: How much of your

personal time in 1988, as the director of OE, did

STICKLEY & SCHUTZMAN, INC.

5

7

8

A. This is a wild guess: I would say 10

percent.

Q. Your involvement, direct involvement with Lincoln actually ended, as I understand it,

in the fall of '88?

My active involvement in terms of

taking any time ended the end of May 1988 with

the execution of the agreement.

Q. And by the agreement we are talking about the MOU, the agreement and the side letter? Supervisory agreement, memorandum of understanding and the side letter, all dated May

A.

20th, 1989.

Q. What percentage of your time from
January 1st, 1988 until May 20th of 1988 would

you estimate was spent on Lincoln?

time.

A. Again a wild guess: 20 percent of my

Q. What exactly was your group, the office of Enforcement, doing to pursue the cease and desist that you had decided to pursue?

STICKLEY & SCHUTZMAN, INC.