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DEPOSITION OF ROSEMARY STEWART VOL. II

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And I might say, Mike, that if it

continues, I think either we will, you ought to

move on to something else, because I'm going to

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be instructing the witness not to answer.

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I think this really does go beyond the pale of this case.

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Q. (BY MR. GALLAGHER) Are you aware that Mr. Wall told representatives of Lincoln that Mr. O'Connell would be taken off of the exam?

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na'an?

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THE WITNESS: I was with Mr. Wall when he

Bet with Mr. Keating and at a particular meeting

when Mr. Keating complained about Kevin

O'Connel1.

Q. (BY MR. GALLAGHER) When was that,

A. I do not remember.

I remember Mr. Keating complaining.

And Mr. Wall's response was that he believed

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DEPOSITION OF ROSEMARY STEWART VOL. II

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Darrell Dochow had already decided to take Mr. O'Connell off the exam. It was not a promise, it was a statement of what he thought Mr. Dochow had already decided to do.

I spoke with Mr. Dochow immediately after that. This was the conversation that I related earlier where he asked for my advice. And Darrell Dochow said that Danny Wall was incorrect, that he had not made that decision yet; he was considering that decision.

9. Did Mr. Wall not also say that, "If he isn't already off the case, I will take him off

the case"?

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THE WITNESS: Be did not.

Q. (BY MR. GALLAGHER) okay. Who else was present at that meeting besides you, Mr. Wall and

Mr. Keating?

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A. I believe that was all. There may have been one other Lincoln representative. I believe

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Q. Did you have any involvement with the attempted sales, the attempted, yes, the

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because I think Jim is about to object, too.

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Lincoln.

There are specific allegations that the sales did not commence because of conduct of the defendants. And that's the purpose for the

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MR. MURPHY: Mr. Gallagher's quite right:

I am going to object to this line of

questioning. It is beyond this lawsuit.

And so far as I have been able to

determine, Mr. Gallagher has not tied any of this

to any of the defendants in the case.

MR.

GALLAGHER: Well, I haven't tied it yet because I haven't done my discovery on it. But it's also an allegation that it's part of the overall vendetta that we complained of in the Complaint.

MR. MURPHY: By who? By whom? Are you claiming Mr. Black and Mr. Gray were involved in

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DEPOSITION OF ROSEMARY STEWART VOL. II

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this?

MR. GALLAGHER : I don't know. I'm trying

to find out if Mr. Dochow for example or Mr.

Black, I'm asking-

MR. MURPHY: If you ask a question

specifically as to the defendants, I will have no

objection.

MR. GALLAGHER : Well, I'm laying the foundation to find out if she was involved,

first.

MR. MURPHY: I would simply say that I urge you to ask the questions with respect to the defendants, rather than the broad inquiry in which you have been engaged this morning.

MR. MCALEER : In addition to Mr. Murphy's remarks, I would also like to object and state that the question presunes facts with respect to which you have not laid a proper foundation that this witness has any knowledge or talked about her involvement; you have not laid the

foundation.

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MR. MCALEER : No, it was not the question

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DEPOSITION OF ROSEMARY STEWART

VOL. II

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Q. (BY MR. GALLAGHER) Did you have any

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involvement in the purported sales or the

3 attempted sales of Lincoln commencing around

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January of '89?

MR. MCALEER:

THE WITNESS:

Objection.

I was informed about the

various sale offers. I was not ever in a
position to make a decision about them. I would
consider my involvement to be very peripheral.

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Did you review the

THE WITNESS: The person who described the

various sale offers to me was always Al

Sauzynski.

Q. (BY MR. GALLAGHER) Who worked for Mr.

Dochow?

A. Yes.

(Mr. Miller departs the deposition room.)

Q. (BY MR. GALLAGHER) That's who

described them to you?

Do you have any additional knowledge as

to who else might have been involved other than

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