1 2 3 DEPOSITION OF ROSEMARY STEWART VOL. II 297 A. Yes. Q. I would like you to be as specific as you can about those comments. MR. MURPHY: Could you phrase the question 10 11 12 13 14 knows what she is answering? MR. GALLAGHER: Yes, fine. Q. (BY MR. GALLAGHER) As you sit here today, how many comments come to mind? MR. MCALEER: Objection. MR. MURPHY: What I would like you to do is describe what kind of comments you are talking Q. (BY MR. GALLAGHER) All right. What would like you to 2. (BY MR. GALLAGHER) You used the tera comments yesterday. I am inquiring about comments you heard regarding the relationship or Gray. A. Well, I testified yesterday that the STICKLEY & SCHUTZMAN, INC. 1 2 3 5 6 DEPOSITION OF ROSEMARY STEWART VOL. II motion to recuse Ed Gray was the first time that I had seen in one place information about this Q. The only other place you would have seen that would have been from time to time in the clipping service, is that true? A. Well, that's possible, but I don't recall that as being my source. Q. All right. Fair enough. A. And the difficulty here is that, after 298 10 11 12 13 service that I'm having difficulty realizing whether that was when I became aware of and heard that down. Q. What's the date that gives you difficulty? A. After April of '89 when the conservator was appointed, there were many days that the clipping service was entirely Lincoln, or nearly so, and just article after article rehashing the events of the prior year. That's making it difficult for me to determine whether I knew it at the time or whether I have been barraged with STICKLEY & SCHUTZMAN, INC. 3 6 7 MR. MAGGIO: Counsel, we are at the end of video cassette number three. We are off the record at 10:06 a.. (The deposition was at recess.) MR. GALLAGHER: Mark this as the exhibit next in order. (Deposition Exhibit No. 53 was marked for identification.) MR. MAGGIO: We are at the beginning of video cassette number four. 10:17 a. Q. We are on the record at approximately (BY MR. GALLAGHER) Ms. Stewart, let ne order as No. 53, and ask you if you can confira A. Yes. Q. The testimony you gave in written fora was true when it was submitted, correct? STICKLEY & SCHUTZMAN, INC. 1989, Friday, November 17th, would have been the preceding Friday. Let's assume that that's The testimony portion, yes. 10 11 12 correct. 13 You submitted it on the 17th of 14 November? Q. When did you first get notice that you were going to be requested to submit testimony or permitted to submit testimony? During October of 1989, I received a subpoena to appear and testify on October 31. Q. Do you remember when you were subpoenaed, how far in advance of the hearing? Q. Let me try it this way: Can you tell ne approximately how much time you put into the STICKLEY & SCHUTZMAN, INC. 300 DEPOSITION OF ROSEMARY STEWART VOL. II 1 preparation of this testimony, the written 2 testimony? MR. MURPHY : Are you distinguishing between the testimony and the appendix? MR. GALLAGHER : Yes, I meant to. THE WITNESS: I worked on it for about four weeks, but not full-time at all. 2. (BY MR. GALLAGHER) It consists of 59 pages, correct? A. Yes. Q. Did you review documents to assist you in preparing? A. Yes. Q. Did you talk to anyone to assist you in preparing? A. Yes. 17 19 20 21 22 23 24 25 Q. One question I meant to ask you is: After our session yesterday, did you talk about your deposition with anybody other than your counsel? 1. And my husband. Did you review any documents between yesterday's session and the comment of this 'STICKLEY & SCHUTZMAN, INC. COURT REPORTERS TELEPHONE 283-0435 N 301 |