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was called as a witness and, having been first duly sworn by
the notary public, was examined and testified as follows:
I am the senior partner, Simpson, Thacher & Bartlett
national banks which we believe you may have information on,
because of your position as counsel to the bank.
I draw your attention to a memorandum, dated May 13,
1975, and ask you when the first time is that you have seen
To the best of my knowledge and recollection, today.
Do you have any recollection after reading that memor
randum otherwise into the loan transaction made by the Manufact
turers. Hanover Company to Mr. Lance in the spring of 1975?
After reading that memorandum, do you have any recolt
lection of the contents of that memorandum or whether or not
you were involved in any discussion concerning that loan?
I believe I was asked by one or more bank officers,
whether individually or in a meeting, as to whether or not the
fact that one of a possible purchases in an interest of a
national bank in Georgia was related to a person who had some
connection with the Federal Reserve Bank of Georgia, presented
A I would tend to guess that probably a question was
asked whether this was a regulated loan within the meaning of
Do you have any recollection of any of the terms of
Would you, sir, check your records to determine whethe
or not you have any information concerning that loan and, if
available, supply them for us?
(Whereupon, at 11:12 a.m., the taking of the deposi
tion was concluded.)
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
Ny term cxpires March 30, 1979.