DEPOSITION OF ROSEMARY STEWART VOL. I 7 2. okay. Out of how many of these things did you look at, say between 1982 and '89, how many final exam reports requesting some action? MR. WHITE: Objection. I don't think exan reports request action, if that's what you mean. Q. (BY MR. GALLAGHER) Can you answer my okay. Goodness. I really don't have any way of knowing that. Q. Can you tell me if it was more than or less than a 100? A. I would say that my office generally did, again, 50 and 100 requests for formal enforcement action. Q. 50 to 100 in what period of time? Any given year, you mean? A. Well, I would say that would have been, this is really a rough guess, what we were doing in the 86, 87 period. STICKLEY & SCHUTZMAN, INC. 228 DEPOSITION OF ROSEMARY STEWART VOL. I Q. Between 50 and 100 during that period 1 2 of time? 3 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. MURPHY: 50 to 100 what, may I ask? formal enforcement action. MR. MURPHY: Whether they were following an exam or not following an exam? THE WITNESS: As I'm thinking about this, that number has to be much higher, because I'm thinking of the number of enforcement cases that we resolved. Q. (BY MR. GALLAGHER) All I'm trying to exception of very few other times, most of these THE WITNESS : Most of them do not. Q. (BY MR. GALLAGHER) I think you told me that Black's only involvement on the 407 exan after he moved to San Francisco was getting reports at his request to Ms. Sobol, correct? -1. Yes. Q. I didn't, I meant to ask you: Was he involved in any other way with that exam during that time frame, do you know? STICKLEY & SCHUTZMAN, INC. 229 DEPOSITION OF ROSEMARY STEWART VOL. I A. Following his move to San Francisco, he became actively involved in preparing recommendations for enforcement action or working on the request that we had for cease and desist action. Q. So after June of '87, Black was very Buch involved? A. Yes. Q. Who was in charge, if you will, of the San Francisco part of the exam after Black got there? Well, Richard Sanchez would still have been in charge of supervising on the exan Steve Hershkowitz of my office was put in charge of developing a cease and desist case, based upon the recommendation we received in May. Q. And Black was doing what? A. He was assisting the San Francisco district in trying to gather the additional documents that we needed, prepared draft notices of charges, and so forth. -8. Is that a normal function for one in STICKLEY & SCHUTZMAN, INC. 230 A. I believe it was later in the month: Q. Were there any minutes, notes or A. I did not keep any notes. 10 11 12 13 14 15 16 17 18 Q. 19 20 21 22 23 24 Q. Do you know if anybody else did? Q. And the purpose of that meeting was to A. The recommendation. The recommendation? That's right. STICKLEY & SCHUTZMAN, INC. 231 Home Loan Bank. I believe there were one or two 5 6 other people from San Francisco whose names I In the formal course of things, when you received other final reports, was it normal to have a meeting? A. On a significant matter, it would be not unusual to have a meeting either by phone, more commonly by phone. Q. Is this the first one that you ever participated in when there was outside fee counsel involved? A. Yes. 2. Tell me as best you can, please, what the sum and substance of that meeting was. MR. MURPHY: I will object on the grounds of relevance. I don't know what it has to do with this particular lawsuit. MR. GALLAGHER: Well, I guess some of it will depend upon what she tells me. STICKLEY & SCHUTZMAN, INC. TELEPHONE 263-4435 |