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DEPOSITION OF ROSEMARY STEWART

VOL. II

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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.

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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 run on Lincoln Savings?

MR. MCALEER : Objection.

MR. MURPHY : Objection.

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

STICKLEY & SCHUTZMAN, INC.

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THE WITNESS: I do not.

Q. (BY MR. GALLAGHER) Did you ever talk to a reporter, newspaper or magazine reporter about Lincoln between the summer of 1986 and

April 14th, 1989?

I do not believe I did, no.

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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.

(Mr. Miller returns to the deposition

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A. After the conservatorship of Lincoln, there were requests that I talk to the press.

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STICKLEY & SCHUTZMAN, INC.

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DEPOSITION OF ROSEMARY STEWART VOL. II

A. If that was the right time. I thought

it was before.

Q. I was asking you about before.

A. I did not talk to the press before the conservatorship.

Q. Okay. That document, that is dated

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public at or about the time it was prepared, I

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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take it?

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Q.

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A.

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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?

MR. MCALEER:

STICKLEY & SCHUTZMAN, INC.

I would object to the

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DEPOSITION OF ROSEMARY STEWART VOL. II

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question, again continuing my objection from

2 yesterday, on counsel's use of the tera leak or

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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.

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Benstein.

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

(BY MR. GALLAGHER) Is that a document

that your office considered particularly

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DEPOSITION OF ROSEMARY STEWART VOL. II

MR. MURPHY:

Objection. I thought we went

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

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one stamp. I don't know -

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MURPHY: No, but there was no stamp at

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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 documents as confidential. That is all.

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.

Are you

Q. (BY MR. GALLAGHER) all right.
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

the end of 1988, did your office subscribe

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