7 10 11 status as of, what, the end of January 1987? Q. Did you have, did you have an understanding at that point about what this lady, understanding very quickly. And to explain that, I have to back up a little bit. I don't know if it was late December or early January, I had been in a meeting with San Francisco folks talking about Lincoln. And the only document we had at the Statement of Supervisory the time was 12 13 14 15 16 17 Q. You know what: I just went brain You went in a meeting talking with the STICKLEY & SCHUTZMAN, INC. DEPOSITION OF ROSEMARY STEWART VOL. II MR. MURPHY: Yes. MR. WHITE: I don't think she testified to that on these four articles. MR. MURPHY: She certainly has not testified to that on the four articles. And I object to the form of the question and to the use of the word "improperly," because it simply doesn't characterize the previous testimony accurately. MR. GALLAGHER: Well, let's figure that out, then. Q. (BY MR. GALLAGHER) When you testified at Congress that unusual events involving Lincoln included leaking of confidential information about Lincoln by persons within the agency, what MR. MURPHY: I will object. What do you mean what did she mean? You just quoted what she said. MR. GALLAGHER : Yes. MR. MURPHY: If you understand the question, you can answer, but if you don't, you have no obligation to do so. THE WITNESS: Well, we have spoken to this point about my impression that there was a lot of STICKLEY & SCHUTZMAN, INC. 315 1 2 3 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 That was not based upon any factual knowledge that I had; that was my assumption that persons within the agency were responsible. THE WITNESS: I am not sure that every time I say "leak," I meant unauthorized. Q. (BY MR. GALLAGHER) How about when you said it here on page three? A. Page three is really a summary that I believed were unauthorized in their I understand your testimony then is information was leaked by persons within the STICKLEY & SCHUTZMAN, INC. 316 DEPOSITION OF ROSEMARY STEWART VOL. II 1 A. Yes. 2 Q. When you gave this testimony, didn't you consider that to be a fairly significant 317 telling me today, you based it on no facts? MR. MURPHY: You can rephrase the question and ask it in a polite way, and will be glad to let her answer it. Q. (BY MR. GALLAGHER) If my tone of voice offended you, I apologize; that wasn't the intent. I will stand by the question. MR. MURPHY: Would you repeat the question. (The portion requested was read by the court reporter.) STICKLEY & SCHUTZMAN, INC. |