Ro: Karl wanted to know when the Sen. called.

SPECIAL COUNSEL

EX. 531

On November 21, 1989, Ka. Rosemary Stewart testified before the Committee
concerning Lincoln Savings. In both her written and oral statemente, Ma.
Stewart essentially adopted Lincoln's theory of the case regarding a purported
"vendetta" against Lincoln Savings, He. Stewart sads exceptionally harsh
statements attacking my character and that of former Bank Board Chairman Gray.
Subsequently, Ka. Stewart was deposed by counsel for Lincoln's parent, ACG.
As this latter recounts, Ms. Stewart's deposition testizony (TR) is essential
in evaluating the charges made by Ke. Stavart to your Committee. I ask that
this latter be included in your hearing receta,

Before the Committee, Ms. Stewart testified that:

[v]ith the benefit of 20/20 hindsight, I now believe that certain Agency officiala wanted the (407] investigation pursued for the Improper purpose of conducting an investigation to build a case for criminal prosecution.

(Committed Hearing Transcript (Testimony), Part 5, p.274)

At her deposition, Ms. Stewart testified that it was her "suspicion that Chairuan Gray and I were engaged in such an effort. (TR 335) In an effort to establish her 'basis for that suspicion, ACG's counsel asked:

Q.

Was that suspicion grounded on anything that, in part at least, on anything that Mr. Black ever said to you?