10 11 122 MR. MCALEER: Objection. THE WITNESS: One of the allegations that Lincoln had made related to a leak of information. At that time, that was Lincoln's word, not mine Q. Yes. 1. -- that had occurred by a member of the Federal Home Loan Bank of San Francisco, a Mr. And the allegation was that he had received confidential information about Lincoln while he was sitting on the board of the San Francisco Bank, and had then provided it to other competitors of Lincoln. Q. Mr. Jannis was with the Gibralter Savings in Southern California? Jay Jannis. 13 14 15 16 17 18 19 20 21 22 23 24 25 A. He was with another large institution. Q. The putative leak dealt with properties Is that the one we are talking about? Q. Who initiated the IG investigation on STICKLEY & SCHUTZMAN, INC. DEPOSITION OF ROSEMARY STEWART VOL. I 149 1 that? A. My office did. I don't know if we did it directly or if we told Harry Quillian, and he was something that was simple enough that we were So Mr. Bershkowitz initiated a conversation. I don't know if it was directly supposedly got the information from Jay Jannis. 2. A. Yes. And got, I remember that we got the story. Inspector General from our Bank Board had 2. And it was in fact an Inspector A. I remember the Inspector General was looking at it. I haven't seen the report. 8. Is that the only allegation of leak you had heard up until the end of December? 24 MR. MCALEER : Objection to counsel's use of 25 the word leak. STICKLEY & SCHUTZMAN, INC. MR. GALLAGHER : What do you want to call 10 11 12 13 14 15 16 17 18 19 20 21 MR. MCALEER: I have stated my objection for the record. It's a continuing objection to your use of the term "leak." MR. GALLAGHER: Why don't I stipulate you have a continuing objection. MR. MCALEER: I am not testifying either. I have the objection. record. Proceed with the questioning. MR. GALLAGHER: All I am trying to do is make it so you don't have to make it every time. We can stipulate that you don't like the word "leak, and we can roll along. MR. MCALEER: I am being paid to make objections today, so don't worry about - TELEPHONE 283-0495 2 3 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 DEPOSITION OF ROSEMARY STEWART VOL. I MR. MCALEER: And I will continue to zake my objections in that regard, and I have continuing objections throughout this deposition to your use of that word. MR. WHITE: For the record, I am going to object also to the use of the tera based on ambiguity. I'm not sure what you mean, but I would infer that you mean something that is an illegal disclosure. And if you mean illegal disclosure, and you want to use that term to describe it, that's fine. But it's at this point ambiguous. Q. (BY MR. GALLAGHER) Up until December 24th, 1986, was that the only allegations of leaks you were aware of? A. I had been told that there were other incidents of confidential information being disclosed, but that is the only one that was ever identified with any particularity. Q. As you sit here today, are you able to be specific as to any other leaks that were alleged to have occurred prior to The Wall Street Journal article of December 24th, 1986? MR. MCALEER: THE WITNESS: STICKLEY & SCHUTZMAN, INC. Objection. I don't know of any others. 151 DEPOSITION OF ROSEMARY STEWART VOL. I 152 2 3 7 MR. GALLAGHER : Let's mark this as the Let's go off the record for a second. identification.) Q. (BY MR. GALLAGHER) Let me hand you, MR. MAGGIO: Hold on. Let's go off the record here. (An off-the-record discussion ensued.) MR. MAGGIO: Back on the record at 2:32. (BY MR. GALLAGHER) Ms. Stewart, let ze hand you what has been marked as Exhibit 50, 10 11 12 13 14 15 16 17 18 19 can tell? which I understand to be a copy of the December And all I am going to ask you is if |