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was called as a witness and, having been first duly sworn by

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the notary public, was examined and testified as follows:

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I am the senior partner, Simpson, Thacher & Bartlett

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national banks which we believe you may have information on,

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because of your position as counsel to the bank.

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I draw your attention to a memorandum, dated May 13,

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1975, and ask you when the first time is that you have seen

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that memorandum?

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A

To the best of my knowledge and recollection, today.

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Q'

Do you have any recollection after reading that memor

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randum otherwise into the loan transaction made by the Manufact

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turers. Hanover Company to Mr. Lance in the spring of 1975?

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After reading that memorandum, do you have any recolt

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lection of the contents of that memorandum or whether or not

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you were involved in any discussion concerning that loan?

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I believe I was asked by one or more bank officers,

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whether individually or in a meeting, as to whether or not the

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fact that one of a possible purchases in an interest of a

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national bank in Georgia was related to a person who had some

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connection with the Federal Reserve Bank of Georgia, presented

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A I would tend to guess that probably a question was

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asked whether this was a regulated loan within the meaning of

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Do you have any recollection of any of the terms of

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Would you, sir, check your records to determine whethe

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or not you have any information concerning that loan and, if

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available, supply them for us?

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(Whereupon, at 11:12 a.m., the taking of the deposi

tion was concluded.)

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I, Joseph Rogers, the officer before whom the fore

going deposition was tekeri, do hereby certify that the witness

whose testimony appears in the foregoing deposition was duly

sworn by me; that the testimony of said witr.css was taken by

D!E stonographically and thereaftor reduced to typewriting under

my direciion; that said deposition is a true record of the

testimony given by said witness; that I am neither counsel

for, related to, nor employed by any of the parties to the

action in which this doposition was taken; and, further, that

I ain not a relative or employee of any attorney or cousse!

employed by the parties here to, nor financially or otherwise

interested in the cutcome of the action.

Notati Public in'any for
the State of New York

Ny term cxpires March 30, 1979.

DEPOSITION OF ROBERT MCKEAN, JR., PARTNER, SIMPSON,

THATCHER & BARTLETT

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