DEPOSITION OF ROSEMARY STEWART VOL. II 272 1 Upon receiving Lincoln's response, which was June or July of 1987, the attorneys After receiving Lincoln's response, those attorneys began to make a list of things that they would need to know about whether Lincoln was correct, whether additional evidence needed to be gathered to support or refute things that Lincoln was claining. And that process was under way in the 10 11 12 13 14 15 16 17 18 19 20 21 22 23 I believe that was November, because there was and so 24 25 a draft order was prepared and put together. This was at the same time that Lincoln STICKLEY & SCHUTZMAN, INC. A. During the fall there was a draft consent cease and desist order that was prepared, 3 5 7 8 6 The actual preparation of the cease and desist documents did not stop at all in 1987, but it clearly got on the slow path when it was sort representatives began to talk about a consent document. 10 Whether it was an agreement or an 11 order, I'm not sure that was ever clarified. But 19 discussing a consent enforcement document coupled with a transfer of jurisdiction. Q. Committee issued a confidential memorandum regarding Lincoln, correct? A. Yes, we did. MR. GALLAGHER: Would you mark that next in In April of 1988 Enforcement Review appear to be, and I apologize for the quality of the copy, but does it appear to be a true and STICKLEY & SCHUTZMAN, INC. Q. The matters contained in that document were true in your judgment when you prepared it? today? Q. (BY MR. GALLAGHER) Are they still true A. Yes. This document, while I authored it, was also reviewed, and many comments and suggestions were offered to me by other members of the committee. Counsel, off the record. 14 15 16 (An off the record discussion ensued.) Q. (BY MR. GALLAGHER) Who all had input into Exhibit 52, the report? A. I drafted it and circulated it to the neabers during April of 1988 and received comments. It was discussed in at least one of the meetings, formal meetings, about changes that the other committee members desired to make to STICKLEY & SCHUTZMAN, INC. 274 DEPOSITION OF ROSEMARY STEWART VOL. II 1 the recommendation. 2 3 6 7 Q. And that's the final product after people had their chances to make changes? Yes, it is. Q. Was that document then basically signed off on by everybody at the Enforcement Review Committee? A. It was. Q. And in April of '88 was Jordan Luke on 22 23 Q. Anybody else? That was the committee. Q. One thing I meant to ask you earlier is: After the Regardies article, somebody told 24 you an Inspector General report was going to be 25 expanded, is that true? STICKLEY & SCHUTZMAN, INC. 275 5 10 11 12 13 THE WITNESS: I believe I said that I was, I was told that it was either going to be I did not know at the time whether the Inspector General had completed prior investigations into leaks. Q. (BY MR. GALLAGHER) I think that is what you said. A. I believe it was Mr. Wall who told me, 15 Q. 16 After the MOU agreement and the side letter of April 20th of 1988, that you mentioned, 17 were entered into, did in fact Washington take 18 19 20 21 22 23 over the examination of Lincoln from San Francisco? A. Washington began a new examination under Mr. Dochow's supervision. Q. Was it your understanding that that meant that San Francisco would no longer be |