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DEPOSITION OF ROSEMARY STEWART VOL. II

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was requesting a transfer of its district, and
folks began to consider that.

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

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of overtaken by other events. And those other
events were that Lincoln and Bank Board

representatives began to talk about a consent

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document.

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Whether it was an agreement or an

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order, I'm not sure that was ever clarified.

But

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Q. In April of 1988 Enforcement Review
Committee issued a confidential memorandum

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MR. GALLAGHER: Would you mark that next in

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appear to be, and I apologize for the quality of

the copy, but does it appear to be a true and

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Q. The matters contained in that document were true in your judgment when you prepared it?

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Q. (BY MR. GALLAGHER) Are they still true

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A. Yes.

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This document, while I authored it, was also reviewed, and many comments and

suggestions were offered to me by other members

of the committee.

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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

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the recommendation.

Q.

And that's the final product after people had their chances to make changes?

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Q. And in april of '88 was Jordan Luke on

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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?

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DEPOSITION OF ROSEMARY STEWART

VOL. II

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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
initiated or expanded; the Inspector General was
going to look into that.

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.

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Q. After the MOU agreement and the side letter of April 20th of 1988, that you mentioned,

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Was it your understanding that that meant that San Francisco would no longer be

involved?

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MR. MURPHY:

I'm going to object.

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DEPOSITION OF ROSEMARY STEWART VOL. II

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You can answer.

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THE WITNESS: We had agreed that the new exam would be conducted without any involvement

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by San Francisco. That was part of our written
agreement with Lincoln.

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
litigation is beyond me, and I object to it.
MR. MCALEER: I would further like to add
to Mr. Murphy's comments that I believe the
question is vague. I also believe you have not
laid an adequate foundation with this witness to
respond to that question.

Q. (BY MR. GALLAGHER) Was that in fact how matters progressed without the involvement of San Francisco?

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