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DEPOSITION OF ROSEMARY STEWART VOL. II

Q. I notice your testimony contains a

number of references to ethical obligations that
you feel as a lawyer.

Those obligations were important to you

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Q.

What I would like to do is review sone

of this testimony with you and ask you for some
further clarifications or explanations.

I thought the easiest way would be for
me to reference pages, and you could turn to

then.

MR. MCALEER: Object to this line of questioning.

Q. (BY MR. GALLAGHER) On page one in the

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DEPOSITION OF ROSEMARY STEWART VOL. II

MR. GALLAGHER: Oh, she has the index at

the front?

NR. MILLIGAN: Yes.

MR. GALLAGHER: Let's get, make sure we are

working from the same document.

Q. (BY MR. GALLAGHER) What I have in

front of me, Ms. Stewart, is 59 pages of

testimony.

And I'm sorry. I do see that the

index is, all the indices are also numbered.
I'm talking about page one of the body

of the testimony.

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A.

All right.

Q.

You explain that one of your objectives

was the eradication of insider abuse.

By insider abuse do you mean insiders at institutions, or does that also include

insiders at the agency?

A.

Institutions, their holding companies

and their subsidiaries.

Q. You do not have any jurisdiction, if

you will, to work on insider problems at the
agency?

A. I do not.

Q. Your agency enforcement office did not have jurisdiction over criminal matters, correct? STICKLEY & SCHUTZMAN, INC.

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Q. (BY MR. GALLAGHER) You state that you now believe these abuses should have been uncovered by the San Francisco regulators, so

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taken.

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MR. MURPHY:

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has

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that effective enforcement action could have been

What abuses are you talking about?

Objection; I don't think this that question has nothing to do with this lawsuit, so far as I have been able to tell.

THE WITNESS: Well, I'm referring back to the preceding paragraph that insider abuse has contributed to the insolvency of many savings and loans, and it now appears that the failure of

Lincoln had the same type of abuses.

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DEPOSITION OF ROSEMARY STEWART VOL. II

Q. (BY MR. GALLAGHER)

Can you be more

specific as to what abuses you are talking about?

MR. MURPHY: I am going to object to this

line of questioning, unless you can somehow

relate it to this litigation.

MR. GALLAGHER: Well, I tell you what:
Rather than fight about it now, why don't we, I
will move on.

MR. MURPHY: To a different subject? Fine.
Q. (BY MR. GALLAGHER) The same paragraph

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down a little lower you have i.e. underscored,
then you talk about San Francisco's inadequate
work.

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Be a little more specific on what you meant by "inadequate work," would you.

MR. MURPHY: I'm going to object on the sane basis. I don't think that question has anything whatsoever to do with this litigation.

If you can tie, and there are portions of Ms. Stewart's testimony that do relate to the subject of this litigation, but there are a lot of parts of Ms. Stewart's testimony that have nothing whatsoever to do with this litigation.

And I urge you and request that you

restrict your questions to those areas that do

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DEPOSITION OF ROSEMARY STEWART

VOL. II

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relate to the subject matter of the litigation.

MR. MCALEER: Simply note my agreement with

Mr. Murphy's remarks.

MR. WHITE: I would like to join in that.
We will come back to that

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GALLAGHER:

area.

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Q. (BY MR. GALLAGHER) Go to page three, please, say around the middle of the top paragraph.

You say there are certain factual events concerning and affecting Lincoln that were not the nora; then you go on to delineate some of them, which included leaking of confidential

information.

Let's talk about the leaking of

confidential information about Lincoln by persons

within the agency.

Tell me each leak of confidential

information that you had in mind when you offered

that testimony in November of 1989.

MR. MCALEER: Objection, continuing objection to counsel's use of the tera "leak." THE WITNESS: I had in mind the same articles that we have discussed so far in this

deposition:

Newspaper accounts containing

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