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DEPOSITION OF ROSEMARY STEWART VOL. II

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Lincoln, correct?

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A. Yes. And we prepared these particular minutes only with regard to Lincoln discussions. Throughout this same period of time, there are other minutes related to other topics.

Q. What percentage of your time in 1988,
and by your time I mean Enforcement Review
Committee, what percentage of your time in 1988
would you estimate was attributed to Lincoln
versus other activities?

MR. MURPHY: By ERC, by Enforcement Review
Committee, do you mean time spent in the

committee deliberations or in the meetings?

Q. (BY MR. GALLAGHER) The Enforcement Review Committee did things other than just meet, right?

A. Yes. We acted on notational voting

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items.

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Q. I'm talking about all of your effort, all of the Enforcement Review Committee's efforts during '88, whatever they might have been,

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whether in or out of meetings, I would like to

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MR. MURPHY:

know, if you can estimate for me, what percentage
of that time was devoted to Lincoln matters?
I am going to object. I mean

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DEPOSITION OF ROSEMARY STEWART VOL. II

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the fact that the people on these committees had

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a lot of other duties besides the Enforcement

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Review Committee, and if you are asking what
percentage of their time they spent on Lincoln

Batters, seens to me impossible for Ms. Stewart
to know, and the percentage would vary.

If what you are saying is how much of the total ERC's meeting time was spent on Lincoln matters, I can understand that question, and I think Ms. Stewart might be able to understand it. Q. (BY MR. GALLAGHER) Well, I will start

with that one.

of all the meetings you had, what
percentage of them were devoted to Lincoln?
A. Well, between January '88 and May '88,

I would say that half of the committee's time was
spent working on Lincoln and half on other

Batters.

Q. Now does your answer go only to meeting time or does it go to overall time?

A. Meeting time.

Q. Are you able to give me any estimate as

to overall ERC efforts and what percentage of

those were devoted to Lincoln as opposed to other

Batters?

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MR. MURPHY:

I'm going to object for the

same reason I said before; I mean

Q.

(BY MR. GALLAGHER)

if you can do it or not.

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I just don't know

MR. MURPHY: I mean, your latter question just starts talking about individuals on the committee. It's not like the committee is always acting. These people have a lot of different duties, one of which is being on the committee. Jin, if she doesn't know, I presume she is going to tell me that.

NR.

GALLAGHER: Right.

She may know. I don't know.

THE WITNESS: I don't believe I can answer that. Between January and May, this took a considerable amount of our meeting time. I mean we considered this to be a big, significant

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Batter.

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Throughout that time, I continued to

give notational voting items to the members.
They do that in their own time, so I'm not sure
how much time they would have spent on those.

Let me

Q. (BY MR. GALLAGHER) All right.
ask you this, Ms. Stewart: How much of your

personal time in 1988, as the director of OE, did

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Your involvement, direct involvement

with Lincoln actually ended, as I understand it,

in the fall of '88?

A. My active involvement in terms of taking any time ended the end of May 1988 with

the execution of the agreement.

Q. And by the agreement we are talking about the MOU, the agreement and the side letter? Supervisory agreement, memorandum of understanding and the side letter, all dated May 20th, 1989.

A.

Q. What percentage of your time from
January 1st, 1988 until May 20th of 1988 would

you estimate was spent on Lincoln?

time.

A. Again a wild guess: 20 percent of my

Q. What exactly was your group, the office of Enforcement, doing to pursue the cease and

desist that you had decided to pursue?

A. I need to go back to June of 1987.

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DEPOSITION OF ROSEMARY STEWART VOL. II

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Upon receiving Lincoln's response, which was June or July of 1987, the attorneys that were working on this case, that is Steve Hershkowitz and Pillsbury, Madison lawyers, who were being supervised by Bruce Ericson, were already drafting Notice of Charges and attempting to support it with evidence from the '86 exan report and the primary documents that went along with it.

After receiving Lincoln's response, those attorneys began to make a list of things that they would need to know about whether Lincoln was correct, whether additional evidence needed to be gathered to support or refute things that Lincoln was claiming.

And that process was under way in the sunner and throughout the fall of 1987.

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A. During the fall there was a draft consent cease and desist order that was prepared,

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I believe that was November, because there was

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some feeling at the time that Lincoln may be
willing to negotiate for a consent order. And so

a draft order was prepared and put together..

This was at the same time that Lincoln

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