11 12 13 14 15 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 as you were preparing this testimony, correct? MR. MCALEER: Objection. THE WITNESS: Yes. Q. (BY MR. GALLAGHER) And they are important to you today? Q. Yes. What I would like to do is review soRe 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 MR. MCALEER: Object to this line of questioning. (BY MR. GALLAGHER) On page one in the second paragraph, you explain that 303 1 2 3 4 5 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 25 DEPOSITION OF ROSEMARY STEWART VOL. II MR. GALLAGHER: Oh, she has the index at the front? MR. 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. 304 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 Q. You do not have any jurisdiction, if you will, to work on insider problems at the A. I do not. 2. Your agency enforcement office did not have jurisdiction over criminal matters, correct? STICKLEY & SCHUTZMAN, INC. Q. (BY MR. GALLAGHER) You state that you now believe these abuses should have been uncovered by the San Francisco regulators, so 9 10 11 12 13 14 15 16 taken. 17 18 19 has that effective enforcement action could have been 20 21 What abuses are you talking about? MR. MURPHY: 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 24 loans, and it now appears that the failure of 23 2225 25 Lincoln had the same type of abuses. STICKLEY & SCHUTZMAN, INC. 1 2 3 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 7 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. GALLAGHER: Well, I tell you what: will move on. MR. MURPHY: To a different subject? Fine. down a little lower you have i.e. underscored, Be a little more specific on what 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 STICKLEY & SCHUTZMAN, INC. 306 1 2 3 DEPOSITION OF ROSEMARY STEWART VOL. II 307 relate to the subject matter of the litigation. Mr. Murphy's remarks. MR. WHITE: I would like to join in that. MR. GALLAGHER : We will come back to that 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 norm; 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 term "leak." THE WITNESS: I had in mind the same articles that we have discussed so far in this deposition: Newspaper accounts containing STICKLEY & SCHUTZMAN, INC. |