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DEPOSITION OF ROSEMARY STEWART VOL. II

motion to recuse Ed Gray was the first time that

I had seen in one place information about this
supposed feud between the two men.

Q. The only other place you would have

seen that would have been from time to time in

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the clipping service, is that true?

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A.

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And the difficulty here is that, after
April of '88, there was so auch in our clip

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service that I'm having difficulty realizing whether that was when I became aware of and heard

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Q. What's the date that gives you

difficulty?

A. After April of '89 when the conservator was appointed, there were many days that the clipping service was entirely Lincoln, or nearly so, and just article after article rehashing the events of the prior year. That's making it difficult for me to determine whether I knew it

at the time or whether I have been barraged with STICKLEY & SCHUTZMAN, INC.

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DEPOSITION OF ROSEMARY STEWART VOL. II

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it since April of '89.

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Q. As far as the comments go

MR. MAGGIO: Counsel, we are at the end of

video cassette number three.

We are off the record at 10:06 a

(The deposition was at recess.)

MR. GALLAGHER: Mark this as the exhibit

next in order.

(Deposition Exhibit No. 53 was marked for

identification.)

MR. MAGGIO: We are at the beginning of video cassette number four.

We are on the record at approximately

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10:17

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Q. (BY MR. GALLAGHER) Ms. Stewart, let me hand you what the reporter has marked next in order as No. 53, and ask you if you can confirm for me that that appears to be a copy of your written submission to the Gonzalez Committee, accompanied by appendices and exhibits?

A. Yes.

2. The testimony you gave in written form

was true when it was submitted, correct?

A. Yes.

Q. Is it still true today?

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2. I have a calendar that tells me that 1989, Friday, November 17th, would have been the preceding Friday. Let's assume that that's

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correct.

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You submitted it on the 17th of

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November?

is

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A. The testimony portion, yes.

Q. When did you first get notice that you

were going to be requested to submit testimony or permitted to submit testimony?

A. During October of 1989, I received a subpoena to appear and testify on October 31. Q. Do you remember when you were

subpoenaed, how far in advance of the hearing?

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the testimony and the appendix?

MR. GALLAGHER: Yes, I meant to.

THE WITNESS: I worked on it for about four

weeks, but not full-time at all.

2. (BY MR. GALLAGHER) It consists of 59

pages, correct?

A. Yes.

Q. Did you review documents to assist you

in preparing?

A. Yes.

Q. Did you talk to anyone to assist you in

preparing?

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One question I meant to ask you is: After our session yesterday, did you talk about your deposition with anybody other than your counsel?

A. And my husband.

Q. Did you review any documents between yesterday's session and the comment of this

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Q. I'm not familiar with congressional

submissions.

I didn't see anything in the

testimony itself that suggested it was given

under oath.

Can you kind of tell me how that

procedure works?

A. When you appear for testimony, you are
sworn in in the beginning. You then offer, or
the committee agrees to take the written
testimony you have already submitted. And then
you offer further comments, if invited to do so.
Q. Have you submitted testimony to

congressional committees on previous, or senate,
any kind of congressional committee hearings on
previous occasions?

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