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DEPOSITION OF ROSEMARY STEWART VOL. II

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speculation on the witness's part.

THE WITNESS: Any information could have

been provided to the press by others who had it
lawfully, other regulators, other people that
appropriately would have shared it with the Bank

Board.

8. (BY MR. GALLAGHER) Would have shared

it with the Bank Board?

A. That we would have shared it with.

Q. As you sit here today, do you have an

opinion as to whether or not Mr. Black's delivery

of the September 19th, 1986

MR. MILLIGAN: December.

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Q. (BY MR. GALLAGHER) Go ahead. Sorry.

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Q. As you sit here today, do you have an

opinion as to whether or not Mr. Black's

dissemination of information to a Mr. Yang with

The Wall Street Journal in December of 1986 was

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THE WITNESS: I do not.

2. (BY MR. GALLAGHER) Do you know

specifically of any dissemination of information
from the agency to reporters, either directly or

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Q. Which other instances?

A. I can remember a couple of institutions

in Texas that were at the point of refusing to

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Objection.

THE WITNESS: Raised his voice; I believe

that's what we said yesterday.

9. (BY MR. GALLAGHER) Well, let me ask

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One area I got sidetracked on, you were going to tell me about some comments you heard, and then we got bogged down on how events after April of '89 led to confusion.

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I want to know about comments you have ever heard from anybody, I don't care if you heard then last night, any comments you have ever

heard from anybody to the effect that there was personal animosity on behalf of anybody connected with the Bank Board in Washington or San Francisco against Lincoln, ACC or Charlie

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Keating.

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is at least restricted to things she has heard,

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MR. WHITE: I am going to object to the question. I think that has been thoroughly asked and answered throughout yesterday's testimony. MR. MURPHY: So do I. I think it's really unfair to a witness, after taking her through all the conversations yesterday to try to come up with one big catch-all question that then uses

phrase such as personal animosity.

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try.

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But I mean, if you can answer, you may

MR. MCALEER: I would like to join in the objections which have already been made, and also

say that I think the question is grossly

overbroad in nature.

If you want to address it to any

specific persons with regard to specific issues,
then do so. But the breadth of the question is

clearly objectionable.

THE WITNESS:

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The only comments I recall

DEPOSITION OF ROSEMARY STEWART VOL. II

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with respect to personal animosity were from
representatives of Lincoln and ACC.

2. (BY MR. GALLAGHER) It's improper for a federal agency to exercise their investigative powers to conduct fishing expeditions, correct?

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Q. (BY MR. GALLAGHER) Let me refer you to page 23 of your testimony, if you would

NR. MURPHY : Why don't we, if you have a particular point or place, it will be helpful to look at it, so she could understand the content. MR. GALLAGHER : All right. It was simply prefatory to a question I was going to ask her. MR. MCALEER: I have a continuing objection

to this line of questioning concerning

plaintiff's Exhibit 53.

9. (BY MR. GALLAGHER)

I'm about midway

towards the bottom of the first paragraph.

MR. MCALEER : Also object to the form of

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that question.

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MR. WHITE: What page are you on?

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MR. GALLAGHER:

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THE WITNESS: There has to be a valid civil

purpose for conducting an investigation by an

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