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Q.

Did you ever de anything to attempt to reach an understanding?
A.. Kot on that point, no.

(TR 350-351)

Ms. Stewart's testimony to the Committee contained the charge that there was a "vendetta" against Lincoln. In her deposition, Ms. Stewart clarified har comments:

A.

Q.

My earlier testimony I had said .. I believe I had said that
vendetta to se geant when people vere taking actions that were
not based strictly upon the factual evidence.

The vendetta that I spoke of by San Francisco in my
Congressional testimony was meant to imply their extreme desire
to see Lincoln dealt with the way that they thought was
appropriate and their aggressiveness was always directed as
much at Washington, I believe, as it was at Lincoln.

So, la that sense vendetta attitude meant something very
different to me. San Francisco's rapented attempt to ensure
that whatever they wanted for Linegin had to be the only sourse
that was taken on Lincoln, that's the kind of thing that led to
By using the word vendetta.

You were also asked about your personal knowledge of any
anim, I believe was the term used, that certain individuals
within the agency might have had against either Mr. Keating or
organisations that he is affiliated with, AOC or Lineoin.

Is it correct that the only personal knowledge of any evidence
of such animus that you have is what you have sean given to you
by Mr. Keating, ACC and Lineola?

THE WITNESS: I believe that has consistently been my testimony, yes.

In what you have been given by either Mr. Kesting, AOC or Line in, is there anything in that information that you would consider hard evidence of animust

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THE WITNESS: I don't know if there is such a thing as hard
evidence of animus. It is personal testimony.

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Q.

A.

Did you reach a conclusion that there were bank employees ea
vendetta against Lincein!

No.

(TR 371)

Ks. Stewart testified to Congress that Chairman Gray and I sought to "punish" Lincoln for its opposition to the direct investment rule. (Testimony, Part 1, p. 256) This charge was Bodified under ACC'a questioning:

Do you believe that Black and Gray tried to punish Lincola for
its vocal objections to the direct investment rule?

A.

This is one of these phrases where my choice of words was not
very good. I don't think "punishing" was exactly the right
word.

I think using them as an example of a direct investment
violation is a correct conclusion.

And I don't think that the use of the word "yunishing" vas
very wise choice of verda on my part.

(TR 301)

She also said:

I do not believe that had Lincoln challenged the (direct investment)
reg, without already being in violation of it, that people would
have had this desire to hold them out as the example.

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The fact was there was a violation, and there was opposition to the
regulation. And I believe that these two things together were
intolerable to Mr. Oray. And I understand that.

(TR.384)

Unfortunately, ACC's counsel did not question Ka. Stewart as to the basia for her claim that I should be "investigated for perjury" because of my criticisme of her side letter" in my testimony to the Committee. (Committee Hearing Transcript, Part 5, p.22)

In any event, while Ke. Stewart acknowledgon that she bears personal animus againat me (Appendix 55), she has not withdrawn her slain as to "parjury," (T2 343-65)

I would like to thank you and the Committee for your past assistance in improving thrift regulation and protecting the taxpayers from further loss. Sincerely,

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SPECIAL COUNSEL

Senator's

Phone call list
and Messages

38-020-91 - 6

SPECIAL COUNSEL
EX. 536

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