1 2 3 5 6 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 Q. The only other place you would have seen that would have been from time to time in the clipping service, is that true? A. Well, that's possible, but I don't recall that as being my source. Q. All right. Fair enough. A. And the difficulty here is that, after 298 10 11 12 13 service that I'm having difficulty realizing whether that was when I became aware of and heard 19 20 21 22 23 24 25 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. 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. 10:17 a. are on the record at approximately Q. (BY MR. GALLAGHER) Ms. Stewart, let ne hand you what the reporter has marked next in order as No. 53, and ask you if you can confira for me that that appears to be a copy of your written submission to the Gonzalez Committee, accompanied by appendices and exhibits? A. Yes. Q. The testimony you gave in written form was true when it was submitted, correct? Yes. Q. Is it still true today? STICKLEY & SCHUTZMAN, INC. 299 9 10 11 testimony was submitted? A. The Friday before the Tuesday appearance. Q. Do you recollect the date of the Tuesday appearance? A. November 21, 1989. Q. I have a calendar that tells me that 1989, Friday, November 17th, would have been the preceding Friday. Let's assume that that's is 16 17 18 19 20 21 22 23 24 25 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? 1. 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? A. A few weeks. Q. Let me try it this way: Can you tell ne approximately how much time you put into the STICKLEY & SCHUTZMAN, INC. 300 THE WITNESS: I worked on it for about four 14 15 16 17 Q. 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? A. Yes. Can you recall who? Q. One question I meant to ask you is: After our session yesterday, did you talk about A. And my husband. Q. Did you review any documents between yesterday's session and the comment of this 'STICKLEY & SCHUTZMAN, INC. 12 13 14 15 16 17 Q. Is this testimony intended to be sworn testimony? A. Yes. 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 testimony you have already submitted. And then previous occasions? Yes. 2. Is that something you do with some 18 19 20 21 22 23 24 25 three other times. STICKLEY & SCHUTZMAN, INC. regularity in your job? A. Not frequently. I have done it two or |