1 2 3 6 7 DEPOSITION OF ROSEMARY STEWART VOL. II relate to the subject matter of the litigation. MR. MCALEER : Simply note my agreement with Mr. Murphy's remarks. MR. WHITE: I would like to join in that. NR. GALLAGHER: We will come back to that Q. (BY MR. GALLAGHER) Go to page three, 307 please, say around the middle of the top paragraph. You say there are certain factual events concerning and affecting Lincoln that were not the nors; then you go on to delineate some of then, which included leaking of confidential information. Let's talk about the leaking of confidential information about Lincoln by persons within the agency. Tell me each leak of confidential information that you had in mind when you offered that testimony in November of 1989. MR. MCALEER : Objection, continuing objection to counsel's use of the tera "leak." articles that we have discussed so far in this deposition: Newspaper accounts containing STICKLEY & SCHUTZMAN, INC. DEPOSITION OF ROSEMARY STEWART VOL. II 2 3 5 6 7 10 11 12 13 14 information from examination findings of our agency. Q. (BY MR. GALLAGHER) Well, we have - yeah, I an a July 1987 I had also asked you about a March 31st, I believe, Orange County article that you disavowed any knowledge about. MR. MCALEER: Counsel, could you be specific about what date you are referring to? 20 21 you gave the year. GALLAGHER: oh. '89. Q. (BY MR. GALLAGHER) I think we have covered The Wall Street Journal article. 22 23 You told me about everything you can remember about that, is that fair? 24. 25 A. Yes. Q. My memory is that you didn't have any STICKLEY & SCHUTZMAN, INC. 308 9 10 11 12 13 14 15 significant remembrance of the Mesa Tribune Am I wrong? ▲. I knew that it was there; I didn't remember the content. Q. And the Regardies article you read at or about the time it was released in July? A. Yes. Q. Tell me about any other specific articles that contained leaks. MR. MCALEER: Objection. THE WITNESS: I talked about the Benstein articles that resulted from the significant that one of those related to Lincoln as well. I 23 24 25 Q. Are you aware, even though you don't. have a specific remembrance of the newspapers and dates, that there were other articles that you STICKLEY & SCHUTZMAN, INC. 1 2 3 7 DEPOSITION OF ROSEMARY STEWART VOL. II felt contained confidential information? it? MR. MURPHY: Can we put a time frame on I think that Ms. Stewart said before, once April 1989 rolled around, all sorts of information came out. MR. GALLAGHER : That's fair enough. or earlier? MR. MURPHY: Do you want to ask her today That's up to you. But I think it would be helpful to put a time frame on it. MR. GALLAGHER : That's fair enough. 10 11 12 MR. MCALEER: Plus I would like to simply 22 23 24 25 MR. GALLAGHER : Okay. MR. MCALEER : Well, you tell me. It's your question. MR. GALLAGHER : Yes, I'm asking her about all articles she had in mind that supported her STICKLEY & SCHUTZMAN, INC. 310 6 7 10 11 12 13 14 15 16 17 18 19 okay. I just want to be clear about that in that question and the THE WITNESS: I did not make this statement with a catalog of articles by my side. I rather Q. (BY MR. GALLAGHER) Really, my only question is, and again, I will limit my questioning to pre-conservatorship, because you have explained that, once that happened, lots of 220 21 please. (The portion requested was read by the court reporter, as follows: Did you have an impression when you gave this testimony --) MR. GALLAGHER: STICKLEY & SCHUTZMAN, INC. Stop. I will re-do it. 311 |