DEPOSITION OF ROSEMARY STEWART VOL. II 2 9 Darrell Dochow had already decided to take Nr. 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. 2. Did Mr. Wall not also say that, "If he isn't already off the case, I will take him off 10 11 12 13 the case"? that was all. Objection. 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 Q. Did you have any involvement with the attempted sales, the attempted, yes, the attempted sale of Lincoln Savings, commencing around January 1989? STICKLEY & SCHUTZMAN, INC. 283 3 because I think Jim is about to object, too. sales did not commence because of conduct of the defendants. And that's the purpose for the I forget what you, if you answered or MR. MURPHY: Mr. Gallagher's quite right: I am going to object to this line of 9 10 11 12 not. 13 14 15 16 17 18 19 20 21 22 23 24 25 And so far as I have been able to determine, Mr. Gallagher has not tied any of this 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 STICKLEY & SCHUTZMAN, INC. 284 DEPOSITION OF ROSEMARY STEWART VOL. II 1 this? 2 3 7 MR. GALLAGHER : I don't know. I'm trying to find out if Mr. Dochow for example or Mr. 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 presunes 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 10 11 12 13 14 15 16 17 18 19 20 21 22 MR. GALLAGHER: That's the question I asked foundation. 285 DEPOSITION OF ROSEMARY STEWART VOL. II 1 2 Q. (BY MR. GALLAGHER) Did you have any involvement in the purported sales or the Objection. I was informed about the various sale offers. I was not ever in a 18 various sale offers to ne was always Al Sauzynski. Q. (BY MR. GALLAGHER) Who worked for Mr. STICKLEY & SCHUTZMAN, INC. 286 5 6 Mr. Dochow directly. Anybody else? I believe that attorneys from the General Counsel's office were asked to begin to look at them in the event that they were The first approval, Informal approval 9 10 11 before they would have really gone up to be 18 19 20 21 22 23 24 MR. (BY MR. GALLAGHER) knowledge from any source, Ms. Stewart, about an California, Register on March 31st, 1989, that contained confidential information about Lincoln? MR. MCALEER: Objection. WHITE: Objection. Do you have any 287 |