by L. J. Taylor
“The old bury them in paper trick.” Charles blew out a breath and slumped back into his chair. “This would go so much faster if I could help you look through those documents.”
“I don’t doubt it,” Kathy said. “But look, they’ve played this trick on the wrong law firm. We’re used to dealing with large volumes of discovery. We’ve already scanned and loaded the documents into a document database program and made them fully searchable. Jim and I can log onto the system, access the documents on our laptops and review them anytime from anywhere.”
Charles perked up a little. “Well at least that’s something. So, how long will it take for you and Jim to finish reviewing those documents and for us to make our next move?”
Kathy grimaced. “It’s slow going with just the two of us. It’s going to take us at least another week just to get our arms around what they’ve given us so that we can complain about what they haven’t. Jim is preparing a chart of the types of documents we have and what we can tell is missing. But he needs more direction from an attorney and, at my hourly rate, it’s just not feasible. With your permission, I’d like to bring on an associate to help out. She’d be able to focus on the project and do it at a lower hourly rate.”
He waved a hand. “I told you money wasn’t a problem. Do whatever you have to do.”
She smiled. “Let’s hope you remember this conversation when you get our bill.”
He returned her smile. “I’m more likely to remember it in the event we win.”
She grimaced. “No pressure. Oh well, I guess I’d better start earning my fee.” She picked up a manila folder and extracted an outline from it. She then folded her hands on the table and gave him a serious look.
Charles’ smile slowly faded. A small frown creased his eyebrows. “What?”
“Have you ever been deposed before?”
“No.”
“Your deposition will probably take place in a conference room in Weisman’s office. I’ll be there, Weisman will be there, a representative of Peachtree and Wilkes might attend, as well as a court reporter and a videographer. Weisman will ask you questions under oath and the court reporter will take everything down. When you answer his questions, there are some important things you need to remember. First, no matter how upsetting or insulting the questions, do not, under any circumstances, go on a rant. Only answer the question asked. Nothing more.”
He raised his eyebrows. “So, based on the fact that I lost my cool during the first press conference, you think I’m likely to go spouting off at the mouth during my deposition.” He shook his head. “That’s not going to happen. I learned my lesson when I saw the replay of that news clip. I promise not to lose my cool anymore - on camera or off.”
“Good,” she said. “Let’s hope you’re a man of your word, because that promise is going to be harder to keep than you can possibly imagine. I learned that the hard way when I was deposed in my divorce case. I thought I had it all under control ---.”
“Wait – you’re divorced?” he asked.
“Yes. Why do you look so shocked by that? Does my being divorced offend your sensibilities?”
“No. It’s just that I imagined you as the quintessential career woman – dedicated to the law and duty and all that. I didn’t see you as the marrying type. So what happened? Did working all hours of the day and night put a damper on things?”
She stiffened. “My personal life has no relevance here. What is relevant is that Peachtree is going to dig into your personal life with a vengeance during this deposition. The point I was trying to make is that, no matter how personal or offensive their questions might seem, you’re going to have to answer them - candidly and without losing your cool. That is, unless I instruct you not to. The deposition will be videotaped and they have the right to play the video at trial. The jury will have the opportunity to see every expression on your face and hear every inflection in your voice,”
“I see.” He tugged at the knot of his tie as if trying to keep it from choking him.
“Not really,” she said, “but you will. I‘ve prepared an outline of potential deposition questions. We’re going to run through them so I can evaluate how you answer them.”
They ran through the list of preliminary background questions about education and employment. Kathy learned a lot about him. She hadn’t known that he was an ex-Marine, for example, or that he and his wife had met when they were both serving in the armed services. She was a Navy nurse assigned to a Navy hospital overseas. They met when he was wounded and she nursed him back to health. It was a story straight out of a romance novel. Kathy couldn’t help but feel a little envious. She got over that feeling quickly when he got to the year of Patricia’s death.
“I was on the road all the time doing book tours and, when I was home, I was locked away writing the next book,” he said. “Patti was complaining about never getting to spend time with me anymore. One morning, we got into a heated argument.”
He paused, getting up to pour himself a glass of water. He sat down, set his cup onto the table and closed his eyes. “That was the last time I ever spoke to her. I told her to stop whining and that I was too busy to deal with her bullshit. I didn’t even tell her that I loved her. ”
Kathy knew the story all too well. It was the tale of many lawyers and other busy professionals whose jobs demanded too much of their time. She imagined that his arguments with his wife were not so very different from the ones she used to have with her ex-husband when she had killed herself working seventy or more hours a week to make partner at her law firm. Eventually, he stopped arguing with her and used her work schedule as an excuse to have an affair with his secretary.
Charles was so obviously in pain that Kathy put her hand over his to comfort him. “Patti knew that you loved her. You were under a great deal of stress. I’m sure she understood that.”
He opened his eyes, turned his hand around in hers and gave her hand a gentle squeeze. “Thank you. I never told anyone else that.”
She wiggled her eyebrows at him to lighten the mood. “We have ways of making you talk,” she said, using what she imagined to be a Transylvanian accent.
He chuckled. “Let’s hope counsel for Peachtree isn’t as good at making me talk as you are.”
She smiled at him, squeezed his hand lightly and then released it. “Okay. Although it’s hard to imagine a line of questioning more intimate than that, the next set of questions is designed to deal with your claim for loss of consortium. Here, they get to ask you questions about your sex life with Patti – whether either of you ever had an extra-marital affair, which one of you prepared the meals, did the housework, and so on and so forth. Would you like to take a short break before we begin?”
He stared at her open-mouthed for a second. “No.” The word came out in a croak.
Kathy smothered a smile and raised an eyebrow.
Charles cleared his throat and gestured for her to proceed.
“So, how would you describe your sex life with your wife?” she asked.
When they were done with that line of questions, the room seemed a little warm to Kathy. She got up to adjust the temperature on the thermostat on the wall. She knew it was completely unprofessional for her to be intrigued by her client’s answers, but she couldn’t help but wonder what it would be like to be married to the man. According to Charles, despite their arguments, he and his wife made love three to four times a week. And they were in their fifth year of marriage. They must have been very much in love and the sex must have been incredible.
Charles watched her adjust the thermostat. “I have a request to make.”
“Yes?”
“Well, it’s just not fair that you get to learn the most intimate details of my life and I don’t get to learn anything about you,” he said. “So, in the interests of fairness, I propose that we go out for drinks later on and you allow me to get to know you a little better.”
She frowned. “Charles, are you asking me out on a date? If so, I ne
ed to tell you that GRH has a very strict anti-fraternization policy. We’re not allowed to date our clients. There are also ethical rules that come into play.”
He shook his head. “No, I just like to know who I’m dealing with. It’s not unusual for attorneys and their clients to network and socialize outside of the office. You and I have never even had lunch together and here we are discussing the most intimate details of my relationship with my wife. I just thought having a drink together after work might be a more conducive setting in which to get to know you.”
It made perfect sense. Here she was accusing the man of wanting to take her out on a date when all he wanted to do was to get to know the person with whom he’d just shared his life story. If she were a man, she wouldn’t think twice about the invitation. In fact, she’d probably relish the opportunity to do a little male bonding with the client over a beer after work. The fact that she was a woman who was undeniably attracted to him tended to complicate things. But she’d have to get over that if she wanted to be successful in bringing in business. “In that case, I’d love to have a drink with you after work. Why don’t we meet at O’Shaughnessy’s Grill on the Beach, at say, eight o’clock?”
He smiled. “Sounds like a plan.”
***
Later that afternoon, Charles Morgan, Sr. stood up to greet his son’s best friend. Tyler Fox was shorter than Mr. Morgan, with a darker complexion and a stocky build. The two men engaged in an elaborate handshake and gave each other a man hug. Mr. Morgan gestured for Tyler to have a seat. He then eased a hip onto the side of his desk. “It’s good to see you, son. How long has it been?”
“Last Thanksgiving when I had dinner here,” Tyler said. He pat his stomach. “There’s nothing like Mama Morgan’s cooking.”
Mr. Morgan chuckled. “I’ve got to agree with you there son. Listen, I asked you to come see me today because I need your help.”
“Anything for you, Mr. Morgan,” Tyler said. “What kind of help are we talking about?”
“Well, you know the lawsuit Charles filed against Peachtree Consulting?”
Tyler nodded. “Yeah, he told me he was going to file the suit and it’s gotten a lot of news coverage.”
“Well, Charles told me the other day that he doesn’t just want to get money out of Peachtree Consulting. He wants to bring the firm down.”
Tyler frowned. “Bring them down? What do you mean by that?”
“He has this crazy idea that Peachtree Consulting was working for a government agency not authorized to conduct domestic operations when the accident happened. He wants to find a way to prove it and then leak that information to the public.”
Tyler leaned forward in his seat. “Mr. Morgan, this is very serious business. If what Charles is saying is true, we’ve got rogue operatives hiring Peachtree to conduct unauthorized operations on U.S. soil.”
“I know. I’m afraid he’s going to get his fool self killed.” Mr. Morgan rubbed his hands over his face then he stood up, walked around the desk, and sat down behind it.
“I tried to talk him out of it, but you know how he is. Once he’s set his mind to something, nothing can stop him. You two are like brothers. Hell, you spent so much time at my house growing up I thought about claiming you on my tax returns. Can you talk to him? If you can’t talk him out of it, can you at least get the F.B.I. to protect him?”
Tyler grimaced. “I’ll talk to him. But you know how the F.B.I. is - strictly by the book. They’re going to want to open up an investigation and they’re going to want him to testify. Does he have any proof?”
Mr. Morgan shrugged. “He didn’t say. The Court did order Peachtree Consulting to produce documents. Maybe there’s something in there.” He shrugged again. “Thank you for helping me with this.”
“No need to thank me, Mr. Morgan. With all those great meals I’ve eaten at your dinner table over the years, it’s the least I can do. Don’t worry. I’ll look into this.”
***
That evening, Kathy walked into O’Shaughnessy’s - a dimly lit Irish pub popular with off-duty Miami Beach police officers. Kathy liked it because it was in her neighborhood, the drinks weren’t watered down and she felt safe. It also served up some pretty good food.
Charles was already seated at the bar with some sort of amber colored liquor in a low-ball in front of him. Kathy nodded and waved at some of the patrons who greeted her. She walked up to him, looked at his glass and raised her eyebrows. “Hi there. I see you’ve started without me.”
Charles smiled and shrugged. “Well, you are five minutes late.”
Kathy grimaced. “Sorry about that. At least five people stopped me on the way out of the office and traffic was terrible tonight.”
The bartender set a glass of pinot noir onto the bar in front of her. “The girl works too hard, I say.” He had a thick Irish accent. “You need to distract her more often. It’s rare to see her out and about before nine of an evening.”
Kathy put an index finger to her lips. “Now, now, Roarke, don’t go telling the man all of my secrets.”
Charles put his elbows onto the bar and rested his chin in his hands. “Please, feel free to tell me everything about her. She knows all about me.”
Roarke chuckled, winked at Kathy and walked away to tend to his other customers.
“Why don’t we get that table in the back over there? We can order something to snack on. I’m starving. I haven’t had anything since lunch,” she said.
“Sounds good.”
Kathy picked up her drink and led the way over to the table. They took their seats, perused the menu and ordered some food.
Kathy settled back into her chair and turned to Charles. “So, what do you want to know about me?”
“Well, I’ve already learned more about you than I knew before,” he said.
“Really? What have you learned?”
“That you like to drink red wine. That you like to hang out in this bar and know half the patrons. That you work late most nights. That tells me you’re a dedicated professional who works long hours and comes in here to decompress. It also tells me that you live nearby, you don’t cook much, you feel safe here and you’re friendly.”
Kathy raised her eyebrows. “That’s very observant of you. I guess I need to be careful who I bring in here lest they learn too much about me. Tell me – how do you know I live nearby?”
“That’s easy,” he said. “You work in downtown Miami, but this bar’s in South Beach. No-one who lives on the mainland would cross the causeway several times a week just to have a drink and some dinner. Besides, the Beach is a logical place for you to live. It’s only fifteen minutes away from your office.”
Kathy nodded. “That makes sense. I can see that. What else have you guessed about me?”
“I’ll never tell,” he said.
Kathy laughed.
The food came. Over dinner, they discovered they had more in common than either of them would have guessed. She discovered that he’d grown up in New York – just like she had. Only he’d lived in Long Island and she’d lived in Brooklyn. She learned that they both liked action movies; however, he didn’t share her enthusiasm for spy novels.
“How can you like action movies and not spy novels?” she asked.
“I can suspend my disbelief for an action movie. It’s not supposed to be realistic. But spy novels? They’re totally unrealistic,” he said.
“How would you know?” she asked.
He shrugged. “My best friend’s an F.B.I. agent.”
Kathy found herself enjoying his company immensely. He was funny and charming and oh, so sexy. She covered her wineglass with her hand when Roarke tried to pour more wine into it.
“Oh no,” she said. “I’ve reached my limit. It’s a school night.”
Charles looked at her quizzically. “You’re taking some classes?”
“No silly. I just meant that it’s a weeknight. I have a hearing in the morning.”
“Oh. Is it a hearing in my c
ase?”
“No. Another one. And I still have some case law to look over before I go to bed. I hate to be a party pooper, but I’m going to have to leave soon.”
“No problem.” He signaled for the check. “Can I give you a lift?”
“You don’t have to. I usually just walk. I’m only a couple of blocks away.”
“It would be my pleasure.”
Charles insisted upon paying the bill. She reached for it when the waitress dropped it onto the table, but he snatched it up first.
“What are you doing?” she asked. “This is on the firm – client entertainment and all that.”
“No, I’ve got it. I haven’t enjoyed good drinks, good food and nice conversation with a pretty lady in a while,” he said.
Kathy frowned. “I’m not a lady, I’m your attorney.”
Charles cracked up. After a second, she joined in. “Wow. Did I just say that? It’s a good thing I turned down that third glass of wine. Lord only knows what would have come out of my mouth then.”
“I’m going to have to get you drunk one day to find out,” he said.
She shook her head and wagged her index finger at him. “No. No. It’s against firm policy to get drunk with clients – you might leave a bad impression.”
“Or a really good one,” he said.
Kathy chuckled.
He paid the bill and they left. He drove a black, late model BMW. He opened the door for Kathy, closed it behind her and then walked over to the driver side and slid in. His car was immaculate - unlike hers which invariably had a layer of sand on it. Living close to the beach caused her car to get sandblasted often. She made a mental note to get it washed.
“Nice car,” she said.