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DEPOSITION OF ROSEMARY STEWART VOL. II

MR. WHITE: Object to the form of the question; it assumes facts not in evidence. MR. MURPHY: It certainly does.

If you want to ask her about whether she knows about the story, that's one thing; but then to add all the lard on all the pejoratives

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MR. MURPHY: Well, I will let your question

speak for yourself, speak for itself.

MR. GALLAGHER: All right.

THE WITNESS: I do not remember a March '89

article.

Q. (BY MR. GALLAGHER) Do you remember any
article around the spring of 1989 out in Orange
County, California, that was followed up by a
on Lincoln Savings?

run

MR. MCALEER: Objection.

MR. MURPHY: Objection.

MR. WHITE: Objection.

THE WITNESS: I do not remember an article

in March.

Q. (BY MR. GALLAGHER) Do you remember an

STICKLEY & SCHUTZMAN, INC.

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Q. (BY MR. GALLAGHER) Did you ever talk

to a reporter, newspaper or magazine reporter
about Lincoln between the summer of 1986 and

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Exhibit 52.

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May I take a look at

I have the impression from someplace that there was a press conference at some point in time discussing Exhibit 52 that you may have participated in.

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A. After the conservatorship of Lincoln,

there were requests that I talk to the press.
Q. Okay.

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DEPOSITION OF ROSEMARY STEWART VOL. II

A. If that was the right time. I thought

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public at or about the time it was prepared, I

take it?

When was it released to the public? Sometime after the conservatorship in April of 1989, and I don't know how much after. Q. All right. Between the summer of 1986 and the conservatorship, you worked on a number of matters involving examinations of institutions

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Q.

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other than Lincoln, correct?

A. Yes.

Q. In any of those other instances were there problems with leaking of confidential information to the press that you are aware of?

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DEPOSITION OF ROSEMARY STEWART VOL. II

question, again continuing my objection from

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yesterday, on counsel's use of the tera leak or
leaking; also object that I don't see how in any
respect this even leads to the discovery of
admissible evidence. And I believe it's going
beyond the scope of permissible discovery.

THE WITNESS: One of the documents that
apparently was received by Mr. Benstein in, I
believe, 1987 was the entire significant

supervisory case report for the Federal Home Loan

Bank Board.

Mr. Benstein used that document to

write articles not only about Lincoln but about a number of other institutions turning each, that particular document has a one-page description of all of the savings and loans that are in our significant supervisory case load. It was called that at the time.

And as a result there were a number of articles about other savings and loans by Mr. Benstein.

Q. (BY MR. GALLAGHER) Is that a document that your office considered particularly

sensitive?

MR. MCALEER : Objection.

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DEPOSITION OF ROSEMARY STEWART VOL. II

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Objection. I thought we went

MR. MURPHY:
through all this yesterday about the degrees of
confidentiality, and decided there was only one.
MR. GALLAGHER : We decided there was only

one stamp. I don't know

all.

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MR. MURPHY: No, but there was no stamp at

MR. GALLAGHER : There was no stamp "this is confidential"?

MR. MURPHY: No, not in the sense that you
are speaking of. There is a designation of
That is all.

documents as confidential.

THE WITNESS: That was a confidential Bank

Board document.

Q. (BY MR. GALLAGHER) Ms. Stewart, there are degrees of significance to documents, even though they may all be confidential, correct?

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MR. MCALEER :

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Objection.

I suppose there are.

Q. (BY MR. GALLAGHER) All right.

Are you

aware of a meeting that Chairman Gray had with

Mr. Benstein, the Regardies author?

A.

No.

Q. Between the summer of 1986 and, let's

say, the end of 1988, did your office subscribe

STICKLEY & SCHUTZMAN, INC.

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