1 2 3 DEPOSITION OF ROSEMARY STEWART VOL. II 273 was requesting a transfer of its district, and The actual preparation of the cease and desist documents did not stop at all in 1987, but it clearly got on the slow path when it was sort 6 7 of overtaken by other events. And those other representatives began to talk about a consent 9 document. 10 Whether it was an agreement or an 11 order, I'm not sure that was ever clarified. But 15 16 Q. In April of 1988 Enforcement Review MR. GALLAGHER: Would you mark that next in 25 appear to be, and I apologize for the quality of the copy, but does it appear to be a true and STICKLEY & SCHUTZMAN, INC. Q. The matters contained in that document were true in your judgment when you prepared it? Q. (BY MR. GALLAGHER) Are they still true 12 A. Yes. 13 14 15 This document, while I authored it, was also reviewed, and many comments and suggestions were offered to me by other members of the committee. 20 21 22 23 "24 25 into Exhibit 52, the report? A. I drafted it and circulated it to the neabers during April of 1988 and received comments. It was discussed in at least one of the meetings, formal meetings, about changes that the other committee members desired to make to STICKLEY & SCHUTZMAN, INC. DEPOSITION OF ROSEMARY STEWART VOL. II 1 2 3 4 5 7 the recommendation. Q. And that's the final product after people had their chances to make changes? Q. And in april of '88 was Jordan Luke on 24 25 Q. One thing I meant to ask you earlier After the Regardies article, somebody told you an Inspector General report was going to be. expanded, is that true? STICKLEY & SCHUTZMAN, INC. 275 DEPOSITION OF ROSEMARY STEWART VOL. II 276 2 5 9 10 11 12 13 14 A. Yes. Q. Who told you that? MR. MCALEER: Objection. THE WITNESS: I believe I said that I was, I was told that it was either going to be I did not know at the time whether the Inspector General had completed prior investigations into leaks. Q. (BY MR. GALLAGHER) I think that is what you said. A. I believe it was Mr. Wall who told me I believe. 15 16 Q. After the MOU agreement and the side letter of April 20th of 1988, that you mentioned, Was it your understanding that that meant that San Francisco would no longer be involved? 25 MR. MURPHY: I'm going to object. STICKLEY & SCHUTZMAN, INC. DEPOSITION OF ROSEMARY STEWART VOL. II 1 2 You can answer. 3 THE WITNESS: We had agreed that the new exam would be conducted without any involvement 5 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 by San Francisco. That was part of our written Q. (BY MR. GALLAGHER) Was that in fact how matters progressed after May 20th, 1988? MR. MCALEER: Objection. MR. MURPHY: I'm going to object on the grounds that questions of this sort have nothing to do with this litigation. We are at the point now where Mr. Gray has left almost a year ago; Mr. Black is in San Francisco. The other two defendants, so far as I'm aware, are not even on the scene. What all of this has to do with this Q. (BY MR. GALLAGHER) Was that in fact how matters progressed without the involvement of San Francisco? STICKLEY & SCHUTZMAN, INC. 277 |