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General Counsel's office were asked to begin to

look at them in the event that they were
determined to be an appropriate application.

The first approval, Informal approval

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before they would have really gone up to be
approved by the Bank Board, would have been Mr.
Dochow and Mr. Sauzynski's organization.

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Q. (BY MR. GALLAGHER)

knowledge from any source, Ms. Stewart, about an
article that appeared in the Orange County,

California, Register on March 31st, 1989, that

contained confidential information about

Do you have any

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DEPOSITION OF ROSEMARY STEWART

VOL. II

288

MR. WHITE: Object to the form of the

question; it assumes facts not in evidence.

MR. MURPHY: It certainly does.

If you want to ask her about whether she knows about the story, that's one thing; but then to add all the lard on all the pejoratives

MR. MURPHY: Well, I will let your question

speak for yourself, speak for itself.

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article.

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MR. GALLAGHER: All right.

THE WITNESS: I do not remember a March '89

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Q. (BY MR. GALLAGHER)

Do you remember any

article around the spring of 1989 out in Orange County, California, that was followed up by a run on Lincoln Savings?

Q. (BY MR. GALLAGHER) Do you remember an

STICKLEY & SCHUTZMAN, INC.

THE WITNESS: I do not.

Q. (BY MR. GALLAGHER) Did you ever talk to a reporter, newspaper or magazine reporter about Lincoln between the summer of 1986 and

April 14th, 1989?

A. I do not believe I did, no.

Q. Let me ask you -- May I take a look at

Exhibit 52.

I have the impression from someplace that there was a press conference at some point in time discussing Exhibit 52 that you may have participated in.

room.)

(Mr. Miller returns to the deposition

Q. (BY MR. GALLAGHER) An I wrong?

A. After the conservatorship of Lincoln,

there were requests that I talk to the press.

Q. Okay.

STICKLEY & SCHUTZMAN, INC.

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DEPOSITION OF ROSEMARY STEWART VOL. II

A. If that was the right time. I thought

it was before.

Q. I was asking you about before.

A. I did not talk to the press before the conservatorship.

Q. Okay. That document, that is dated

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public at or about the time it was prepared, I

take it?

April of 1989, and I don't know how much after.
Q. All right. Between the summer of 1986
and the conservatorship, you worked on a number
of matters involving examinations of institutions

other than Lincoln, correct?

A. Yes.

Q. In any of those other instances were there problems with leaking of confidential

information to the press that you are aware of?

MR. MCALEER:

STICKLEY & SCHUTZMAN, INC.

I would object to the

DEPOSITION OF ROSEMARY STEWART VOL. II

1

question, again continuing my objection from

2 yesterday, on counsel's use of the tera leak or

leaking; also object that I don't see how in any

respect this even leads to the discovery of
admissible evidence. And I believe it's going
beyond the scope of permissible discovery.

THE WITNESS: One of the documents that apparently was received by Mr. Benstein in, I believe, 1987 was the entire significant supervisory case report for the Federal Home Loan

Bank Board.

Mr. Benstein used that document to

write articles not only about Lincoln but about a number of other institutions turning each, that particular document has a one-page description of all of the savings and loans that are in our significant supervisory case load. It was called that at the time.

And as a result there were a number of articles about other savings and loans by Mr. Benstein.

Q. (BY MR. GALLAGHER) Is that a document

that your office considered particularly

sensitive?

MR. MCALEER:

STICKLEY & SCHUTZMAN, INC.

Objection.

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