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A. To the best of my recollection

knowledge, yes.

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Q. Do you know what Mr. Black's role was

with regard to Lincoln after May 20th, 1988?

A. I don't believe he had any role until after the conservatorship.

Q. So as far as you know after May 20th, 1988, Mr. Black had nothing further to do with

the Lincoln exam until the conservatorship, April 14th, 1989?

A. That's right.

Q. Did I understand you to say, Ms.

Stewart, that after these documents were executed

on May 20th, 1988, your active involvement at
least changed?

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that nature?

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A. My active involvement ceased. I
continued to be consulted or to get involved
peripherally as the new exam was under way.
Q. Did you review materials, things of

Objection.

Only very, very limited

documents did I ever look at after May.

Q. (BY MR. GALLAGHER)

Are you aware of

any instance after May 20th, 1988, where anyone

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DEPOSITION OF ROSEMARY STEWART VOL. II

on behalf of Lincoln expressed concerns about

Kevin O'Connell being involved in the Lincoln
exan?

MR. MURPHY: Objection; that has nothing to

do with this litigation.

MR. GALLAGHER : It sure does, Jin; it is in the Complaint.

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Complaint, but it has nothing to do with the four defendants, unless you can tie in one or more of

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conspiracy claim that I think gives me a right to find out what the big picture was. And Judge

Bilby has said that Ms. Stewart's deposition will

progress as a normal deposition without the

limitations that have been imposed on Mr.

Dochow's deposition, and presumably other party

defendants'.

And I think I have a right to at least find out whether or not she is aware of this kind

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DEPOSITION OF ROSEMARY STEWART VOL. II

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of complaint, and if anything was done about it.

That's all I have asked her.

MR. MURPHY: I object to it. That portion

of the Complaint has been dismissed.

It is not

relevant to the four people who are defendants in

this case.

If you can tie one or more of those defendants to the question that you have asked, then I might, I would withdraw my objection. unless and until, I must persist.

But

MR. MCALEER: I would like to state for the record that I object to counsel's attempt under the pretense of a vague conspiracy count involving, as I understand the allegation, Mr. Black and Mr. Gray abusing discovery in this action and attempting to say that all flows fron that vague conspiracy count.

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that?

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Notwithstanding counsel's comment, I don't believe that Judge Bilby has permitted such an abuse of discovery. And I would object to counsel's attempt to justify everything on that

basis.

Q. (BY MR. GALLAGHER) Have you ever heard

I recall the complaint being made.

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Q. Would you tell me what you did or what

happened.

A. Darrell Dochow asked my advice about whether he should, what he should do in regard to

this complaint.

Q. What did you tell him?

A.

I told him I did not believe he should take Mr. O'Connell off the examination, he was

too valuable.

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At that point in time, presumably Mr.
Dochow knew that Kevin O'Connell was Bill

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asked and answered.

-- as to what Mr. Dochow

knows, and a continuing objection to this line of

inquiry.

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DEPOSITION OF ROSEMARY STEWART VOL. II

And I might say, Mike, that if it

continues, I think either we will, you ought to

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move on to something else, because I'm going to

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pale of this case.

MR. MCALEER: I would like to note my

agreement with Mr. Murphy's remarks.

MR. GALLAGHER : Although I don't have many

nore, I'm going to try a couple more.

We can call the Judge or do whatever we

want to do.

Q. (BY MR. GALLAGHER) Are you aware that Mr. Wall told representatives of Lincoln that Mr. O'Connell would be taken off of the exam?

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THE WITNESS: I was with Mr. Wall when he

Bet with Mr. Keating and at a particular meeting

when Mr. Keating complained about Kevin

O'Connell.

Q. (BY MR. GALLAGHER) When was that,

1. I do not remember.

I remember Mr. Keating complaining.

And Mr. Wall's response was that he believed

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