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and at the same, if you want to continue along

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this line, Mr. Gallagher, we will take a recess until we all get a chance, until you get a chance to relax a little bit.

But if you have a question, fine; but you know, to come out with rhetoric of the sort you have just been doing, I really urge you not to do it. I mean, up until now we have been reasonably cordial to each other, all three of us, and I really urge that we continue to do that.

MR. GALLAGHER : I would like to continue to be cordial, and I would like an answer to questions that I ask. And I don't believe I have

gotten an answer to that question.

Q. (BY MR. GALLAGHER) And I do not mean by my tone of voice to personally offend you; that's simply my style in interrogating.

MR. MURPHY : Well, in this instance I urge you not to use that style, because we won't tolerate that style, whether it be your normal style or not.

MR. GALLAGHER:

All right. I think enough

has been said on that; now back to my question.

Q. (BY MR. GALLAGHER)

You have told me

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DEPOSITION OF ROSEMARY STEWART VOL. II

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you had an event in mind, Ms. Stewart, when you

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used the language agency officials. I'm now
asking you what people you had in mind when you
used the tera officials.

MR. MURPHY: Object to the question; you haven't laid the foundation that she had specific people in mind.

You have to ask a foundation question.

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Black.

MR. MCALEER: Objection; same foundation.
MR. MURPHY: Objection; same foundation,

question.

You still haven't established that she

had particular people in mind

THE WITNESS: My (suspicion was that Mr.

Gray had made the decision about the

investigation based on the recommendation of Mr.

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question.

MR. WHITE: Objection; she didn't testify

to that.

THE WITNESS : That was my suspicion.

Q. (BY MR. GALLAGHER) Was that suspicion grounded on anything that, in part at least, on anything that Mr. Black ever said to you?

A. NO.

Q. Was that suspicion grounded at least in part on anything that you ever heard Mr. Black was supposed to have said to someone else?

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regard to Mr. Gray: Was it based at least in

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part on anything that Mr. Gray ever said to you?

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THE WITNESS: Yes.

Q. (BY MR. GALLAGHER) Tell me about that,

please.

A. It was based upon the information contained in Lincoln's motion to recuse Ed Gray, many of which attachments were purported quotes of Mr. Gray. It's based upon information contained in the lawsuit filed by Lincoln for the leaks, which, again, contained information about things that Ed Gray had said or done. And it was based upon information described to me by Charlie Keating, who had heard secondhand about comments

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Q. (BY MR. GALLAGHER)

any attempts to independently verify any of

whatever it was Mr. Keating told you?

A. No.

Did you ever make any attempts to independently verify any of the information that you had come across in the recusal motion?

A. No.

2. Did you ever have any conversation with anybody at the agency about your feeling that Black and Gray were pursuing the exam for

improper purposes?

MR. MURPHY: Would you repeat the question,

please.

(The portion requested was read by the

court reporter.)

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MR. MURPHY: If you would substitute the
word "suspicion" for "feeling," I think that
would at least begin to be more accurate.
think Ms. Stewart chose that word fairly
carefully. And I think it would

MR. WHITE: I also, we object to the use of

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