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DEPOSITION OF ROSEMARY STEWART

VOL. II

282

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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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be instructing the witness not to answer.

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I think this really does go beyond the pale of this case.

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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 exan?

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THE WITNESS : I was with Mr. Wall when he

met with Mr. Keating and at a particular meeting

when Mr. Keating complained about Kevin

O'Connell.

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DEPOSITION OF ROSEMARY STEWART VOL. II

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Darrell Dochow had already decided to take Mr. O'Connell off the exam. It was not a promise, it was a statement of what he thought Mr. Dochow had already decided to do.

I spoke with Mr. Dochow immediately after that. This was the conversation that I related earlier where he asked for my advice. And Darrell Dochow said that Danny Wall was incorrect, that he had not made that decision yet; he was considering that decision.

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Did Mr. Wall not also say that, "If he isn't already off the case, I will take him off

the case"?

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THE WITNESS : He did not.

Q. (BY MR. GALLAGHER) Okay. Who else was present at that meeting besides you, Mr. Wall and

Mr. Keating?

A. I believe that was all. There may have been one other Lincoln representative.

I believe

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Q. Did you have any involvement with the attempted sales, the attempted, yes, the

attempted sale of Lincoln Savings, commencing

around January 1989?

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because I think Jim is about to object, too.

There is a damage claim in this. One

of our allegations is that the conduct complained

of in the Complaint resulted in damage to

Lincoln.

There are specific allegations that the sales did not commence because of conduct of the defendants. And that's the purpose for the questioning.

I forget what you, if you answered or

MR. MURPHY: Mr. Gallagher's quite right:

I am going to object to this line of
questioning. It is beyond this lawsuit.

And so far as I have been able to

determine, Mr. Gallagher has not tied any of this

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not.

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to any of the defendants in the case.

MR. GALLAGHER: Well, I haven't tied it yet because I haven't done my discovery on it. But it's also an allegation that it's part of the overall vendetta that we complained of in the Complaint.

MR. MURPHY: By who? By whom? Are you claiming Mr. Black and Mr. Gray were involved in

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DEPOSITION OF ROSEMARY STEWART VOL. II

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this?

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MR. GALLAGHER : I don't know. I'm trying

to find out if Mr. Dochow for example or Nr.

Black, I'm asking-

MR. MURPHY: If you ask a question

specifically as to the defendants, I will have no

objection.

MR.

GALLAGHER : Well, I'm laying the foundation to find out if she was involved,

first.

MR. MURPHY : I would simply say that I urge you to ask the questions with respect to the defendants, rather than the broad inquiry in which you have been engaged this morning.

MR. MCALEER : In addition to Mr. Murphy's remarks, I would also like to object and state that the question presumes facts with respect to which you have not laid a proper foundation that this witness has any knowledge or talked about her involvement; you have not laid the

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DEPOSITION OF ROSEMARY STEWART VOL. II

Q. (BY MR. GALLAGHER) Did you have any involvement in the purported sales or the attempted sales of Lincoln commencing around January of '89?

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various sale offers. I was not ever in a
position to make a decision about them. I would
consider my involvement to be very peripheral.

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various sale offers to me was always Al

Sauzynski.

Q. (BY MR. GALLAGHER) Who worked for Mr.

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