did you first find out Mr. Black was going to be

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there?

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No; not in front of anyone, no.

Q. And afterwards you had a conversation with him where he told you that the chairman had

asked him to come?

question.

Q. (BY MR. GALLAGHER) Can you not answer

the question?

A. I wouldn't know.

Q.

Did any participant in the meeting

display any conduct that you found to be unusual

for a meeting of that type?

MR. MCALEER :

Objection.

I'm going to object on the

A. My own personal opinion was that Mr. Black was very aggressive at the meeting at a time when we were resolving the problem for which

the meeting had been called.

2. How did that aggression display itself?

A.

Comments about what would happen if

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MR. MURPHY: Objection; that's not what the

witness testified to.

MR. GALLAGHER: I don't know. That's why I

an asking.

MR. MURPHY: I am going to object to the
Once again, you are

form of the question.

leading impermissibly.

Q. (BY MR. GALLAGHER) What was the nature

of these threats as you would describe then?

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A. Mr. Black told then that they could

have some litigation on their doorstep, if it did not get resolved quickly and inmediately in the manner that we were discussing.

Q. Any other specific comments you recall having been made by Mr. Black in that meeting?

A. He repeated more than one time what the agency would not tolerate by way of lack of

cooperation.

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DEPOSITION OF ROSEMARY STEWART VOL. I

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Q. Did you view that as kind of an unusual

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MR. MURPHY: I'm going to object to that.

THE WITNESS:

I had begun the meeting by describing what we thought was acceptable conduct.

And my recollection is that Bill Black

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had come late to the meeting. So at the time, I

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was not certain in my own mind, maybe he hadn't
heard ne, maybe he hadn't realized that we
started with a clear statement of what was
expected of Lincoln in connection with that

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examination.

Q. (BY MR. GALLAGHER)

My question really
Wasn't his conduct and his statements,

weren't his statements a little unusual in your
15 years or so experience at a first meeting?
MR. MCALEER: Objection.

MR. MURPHY: Object to the form of the

question.

.NR. MCALEER: Let me be clear. I don't

believe her testimony was exactly how you are

posing the question.

I think her testimony was this was her

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Go ahead.

Q.

I have lost track of where we are.

This was the first time that you, and

as far as you knew, Mr. Black had met with
Lincoln representatives, correct?

A. That's right. I had spoken on the
phone with Mr. Fischbein once or twice prior to
this meeting.

Q. You have had lots of first meetings with institutions over the course of your

experience, correct?

A. When an enforcement attorney attends a meeting, it's generally intended to be the only meeting.

Q. Okay.

• We try to resolve the matter then.

Q. All I'm trying to get is an honest answer whether or not Mr. Black's conduct was

unusual in your view.

A. I found it to be very aggressive.
Whether it was unusual is probably a question of

style rather than anything else.

2. It's true, is it not, that he was

raising his voice, waving his arns, and going

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