by Cara Putman
“What the death certificate required.”
“What happened to Miguel Rodriguez?”
“What do you mean?” Mr. Snowden’s features hardened into a mask.
“When did he arrive here?”
“I can’t tell you off the top of my head.”
“Did you review his file in preparation for this deposition, as the summons requested?”
“No.”
So this was how he wanted to play it. Fine. She pulled a copy of the request for deposition from a legal pad and handed it to the court reporter. “Would you mark this Exhibit A?”
The woman filled out the sticker and affixed it to the front of the document, then handed it back to Hayden, who handed the labeled copy to Snowden and a second to Beauman. “This is a copy of the request that was mailed to you.”
“Okay.”
“Did you read the request when received?”
“I forwarded it to our counsel.”
“Mr. Beauman?”
“Yes.”
“Did he read the document?”
“He told me how to prepare for today.”
“How did he tell you to prepare?”
Beauman glared at Snowden, but the director kept talking. “He told me to leave the file to him.”
“Objection. The answer is outside the scope of the deposition.”
She stared at Beauman. “No it’s not. It’s why we’re here.”
He pointed at the court reporter. “Note my objection for the court.”
“Already done.” The woman looked at Hayden and rolled her eyes.
“Please answer the question.”
CHAPTER 33
There’s nothing to tell.” The director set his chin in a stubborn jut.
“I can get a judge involved.”
Beauman grinned at her, a gotcha grin that set her teeth on edge. “Actually, you can’t. There’s no judge overseeing this deposition.”
“I’m happy to get a magistrate involved. That’s what they’re appointed for.”
“Not in this part of Texas. They like attorneys to work out differences without involving them. Much more important things demand their attention.”
Hayden stared at him, but he didn’t back down. Could she force the issue with a magistrate who wouldn’t have jurisdiction? She did not want to tip this pompous attorney off to her legal theory. One call to the Court of Federal Claims was all it would take to lay out her strategy. What she wouldn’t give to have Gerard a call away.
She turned back to Snowden. “Looking at the request I’ve handed you, doesn’t it request a copy of Miguel’s file?”
“Does it?”
She smiled around a clenched jaw and pointed out the page and line.
“Somehow I missed that.” Snowden leaned forward and pressed a button on his phone. “Eudelia, could you find Miguel Rodriguez’s file and copy it for our guest?”
Her reply came over the speaker. “Sir, you know that file’s—”
Snowden picked up the phone before his assistant finished. “Just get it.” He hung up. “Anything else?”
“Yes.” She glanced at her notes and forced herself to take several breaths before she restarted. “Who worked the night Miguel Rodriguez was killed?”
“Which night was that?” Snowden held his hands in front of him. “I don’t have his file in here.”
She’d bet money the file had conveniently disappeared. She pulled out a copy of the death certificate. “Please mark this as plaintiff’s Exhibit B.” The court reporter did so and returned it to her. Hayden then gave that to Snowden and an extra copy to Beauman. “This document is a copy of Miguel Rodriguez’s death certificate. What date does it list as his date of death?”
“January 23, 2017.”
“And what does it list as the location of death?”
“The juvenile detention facility.”
“Which is?”
“This facility.”
“And what does it list as the cause of death?”
“Murder.”
“January 23 was less than three months ago. Do you want me to believe you don’t remember that occurrence?”
“Objection.” Beauman examined his manicure as if nothing interesting had happened. “Argumentative.”
“So noted.” The court reporter nodded at Hayden.
“Let me rephrase. Do you remember the events detailed on the death certificate?”
“No.”
“Really?”
“Argumentative.” Beauman grinned. “You’ll have to try harder, counselor.”
Hayden puffed out a breath. “You don’t remember a young man detained in your facility being murdered?”
“No.”
“Why?”
Snowden smiled, a tight-lipped gesture. “I was in the hospital recovering from gall bladder surgery.” He gestured toward Beauman. “He has a copy of the relevant medical records.”
Hayden continued the deposition, but her passion felt blunted. The director was still responsible for what happened on his watch, but the fact he wasn’t on site for two weeks around the murder meant he might not have directed the cover-up. But someone had, and that someone reported to Snowden. As the saying went: the buck stopped here.
She moved him through a series of questions regarding who had access and how. “If it’s as safe as you say, why not give me the video from Miguel’s room the day he died?”
Mr. Snowden heaved a large sigh. “Complete the FOIA request, and I’ll send what we have.”
“How long does your video store?”
“Thirty days, give or take.” He glared at her. “Even low resolution takes a massive amount of server space. Now if you’re ready to continue.”
Her mind raced as she realized that time had expired. The video she needed could be gone, but if she filed the complaint tonight and filed a discovery request with it, maybe she could locate what she needed. But a quick glance at her watch affirmed the court had already closed. There was nothing she could do tonight but finish the deposition.
An hour later, the deposition whined to a stop.
“I’ll transcribe the deposition this week and send a copy to each of you. Mr. Snowden, you’ll have thirty days to review and make any changes. Otherwise, it will stand as transcribed.” The court reporter packed up her equipment and left after exchanging cards and a bill with Hayden.
Beauman watched her leave and then extended his hand. “Get what you need, counselor?”
“You’ll know soon enough.” She batted her eyelashes at him and extracted her hand from his. “Always a pleasure to meet the DOJ’s finest.”
He nodded an acknowledgment, then grabbed his briefcase and turned to Snowden. “I’ll be in touch, Director.”
Since his assistant had left for the night, Director Snowden escorted Hayden toward security, but not before one of the guards gestured for her to wait. She slowed her steps, and the guard came closer. “Wait for me outside when you leave.”
As Mr. Snowden turned around to check on her, the guard returned his attention to his station.
“May we continue?”
Hayden nodded and hurried to catch up. What did the guard want to tell her that he couldn’t say in front of Snowden?
Half an hour later, Hayden sat inside her car, her stomach growling. How long would she have to wait for the guard to arrive?
The kids might be cared for at a basic level, but Director Snowden hadn’t let her see any. Someone knocked on her car window, and she startled before lowering it a crack.
The guard leaned toward the window, meeting her gaze through the crack. “You’re still here.”
Hayden nodded. “I’d have waited longer.” Though not much.
The man was solid and looked like he’d spent serious time in the military or border patrol. His biceps bulged beneath the edges of his T-shirt. He glanced around, then nodded toward a beat-up Dodge pickup. “Follow me to town, and we can talk.”
“Okay.” Was it smart
to follow him? Surely as long as they stayed in public she’d be okay. She started the rental, pulled out, and followed him along the road. Only two people knew where she was, and no one would know where to look if she disappeared.
You’ve read too many thrillers, Hayden. Nothing will happen.
It took a few minutes of trusting him before her GPS finally synced up. She never wanted to live anywhere so remote that GPS struggled to find its satellite. As they entered town, she drove by the sole hotel, where she’d spend the night. Then he pulled into the parking lot of a place that looked more like a bar than a restaurant. An odd assortment of dusty pickup trucks, sedans, and one VW Bug filled the parking lot.
He waited for her and held the door like a gentleman, and Hayden felt her spine relax just a bit. Public was good. Very good. And acting like his momma raised him with manners? That helped more than a bit.
The inside of the tavern smelled musty, like decades of cigarette smoke had soaked into the walls before public smoking bans took effect. The smell of fried food sat on top of the smoke, coupled with the sound of an old jukebox playing country music and the crack of pool balls. The lighting was decent for a large room, with two windows at the front. Florescent bulbs lit the darker recesses.
The guard nodded at the waitress, then led Hayden to a corner booth. He claimed the side facing the door, so she eased opposite him, cracked vinyl catching her hose as she slid across.
“Why are you here?” His words were harder than his tone.
“I’m looking into Miguel Rodriguez’s death.”
His dark gaze bored into hers as if testing her words. He gave a slow nod. “Why?”
“His grieving mother needs to know what happened.” This guard didn’t need to know about the pending lawsuit.
The waitress sauntered up with her order pad held out and a ready smile for the guard. “Roy, what can I get you tonight?”
He ordered a beer and burger, and only then did the buxom waitress turn to Hayden. “And you?”
“A glass of water and a bowl of chicken noodle soup.”
The woman made a note on her pad, then left, and Roy returned his focus to her.
“So your name is Roy. Care to give me your last name?”
“It’s not important.” His gaze hardened, and she felt a whisper of fear. This was a man who could hurt her in a moment, yet even as his gaze chilled her, she sensed he didn’t intend to. “What’s the real reason you’re here?”
“Miguel Rodriguez.” She refused to flinch under his scrutiny.
“Why care about one more Latin American kid entering the country illegally?”
“If you were his parent, you’d care.”
“If I were his parent, I wouldn’t send him the coyote way.”
Hayden placed her hands on the table and met his gaze. “You’re right. You and I wouldn’t. But we’ve never been desperate enough to be willing to do anything to save our child.” She took a deep breath as images of other refugee children filled her mind. “His mother didn’t send him that way, and she deserves to know what happened.”
“And the other kids?”
She stilled. “Other kids have died in detention?”
He shook his head. “The other kids there. Do they matter?”
“Absolutely.”
“Do they matter to you?”
His question went deep. She wanted to insist they did, but something inside her prevented the lie. She hadn’t cared about them until she learned about Miguel. Even then, her focus was defined. She hadn’t considered other kids in his position.
“There are hundreds more kids in that facility, and nobody’s doing anything to move them through. They linger for weeks and months. Some have lived there a year.” He shook his head. “Five days a week, I watch these kids devolve. There’s little school. Little medical care. And nothing the director can do about it. His best isn’t much.”
“Help me figure out what happened to Miguel, and I’ll do what I can to help the others. I have to start somewhere. Miguel is someone I can focus on and make a difference.”
“That’s where you’re wrong, lady.” Roy’s Texas twang deepened. “He’s dead. There’s nothing you can do that matters to him. It’s the other kids who need your attention.” He studied her but must not have found what he sought, because a look of defeat settled on his face. “I wasn’t working the night Miguel died. One of my friends was. I’ll see if he’ll talk to you.”
“I need a real tour of the facility too. One where I can examine where he lived and see the conditions up close.”
“Even if I can do that, it’s different from when Miguel was here.”
“What’s changed?”
“Little things. The kids had free access to each other’s rooms. Now it’s key card access, like a hotel. Doors kept closed all the time.”
“That must have cost a pretty penny.”
“It did. What else could he do?”
She considered his words, but knew it was important—not just for Miguel, but for the other kids—to see what it was really like. “I need to visualize it so I can create the scene for a jury.”
He grinned, and Hayden realized her mistake. “That’s what I wanted to hear. I knew this had to be bigger than one kid.” He took a swig of his beer, then slapped a hand against the table, and Hayden jumped. “There’s a congressional tour tomorrow. Maybe I can get you on that, and you can slip away to your own tour.”
“That might work. Who’s the congressman?”
“Some bigwig. Someone who listened to my calls.” He pulled out his phone and typed a message.
The waitress delivered their food as he tucked his phone away. Hayden watched as he dove into his food, her bowl of soup looking small next to his half-pound burger.
“Why do you work there? If it bothers you to see the kids like that?”
He swallowed his bite and set down the burger. He rested his elbows on the table and looked past her. “My grandfather immigrated as a teen. He walked across the border to a new life. It was hard, but he had a community to help him.” He shrugged. “These kids, there’s nobody to help. So I try. It’s not much, but maybe I can ease their fear and protect them while they wait.”
His words soaked into her mind. “Do they need protecting?”
“The little ones do. There are gangs here. Anywhere there is a void, evil likes to take a foothold.” He looked at her again. “I do my part to keep it at bay.”
“But you couldn’t for Miguel.”
Roy shook his head. “No, but I don’t want it to happen to anyone else.”
“Did you know Miguel?”
“Not really. With so many detainees, I can only know twenty or thirty. He was quiet. Kept to himself. Always watching, like he expected something to happen.”
“Was he friends with anyone?”
“He was a loner.”
“Surely he had at least one friend. Someone he hung out with.” She didn’t want to imagine him so alone.
“He didn’t.” Roy’s phone vibrated, and he tapped the screen. “My buddy will meet you for an early breakfast, then get you on the tour.” He threw a twenty on the table and stood. “Be here at seven. The waffles are good.”
“How will I know who he is?”
“He’ll know you.”
Hayden turned and watched Roy stride from the room. The slightest bit of swagger affected his walk. The waitress approached with the bill. “Need anything else?”
Hayden looked down at her half eaten bowl of soup, but her appetite had vanished in nerves for the morning. “I’m fine.”
As she walked to her car, her gaze took in the surrounding area. She slid behind the rental’s wheel and used the rearview mirror to scan behind her. There were so many shadows she didn’t see anything until she pulled out and the headlights swept the area. Then her pulse raced as her foot jerked on the gas pedal. Director Snowden stood by the Dumpster, watching.
CHAPTER 34
Hayden was still shaking when
she pulled into the motel parking lot. The small Texas town didn’t have options, so she’d booked the only room she could. Should she search somewhere else, somewhere Director Snowden couldn’t easily find her? But with a seven a.m. meeting, driving the forty-five minutes to Waco wasn’t appealing.
Even so, she drove around the small parking lot to diffuse the shadows before she parked. Then she pulled her rolling suitcase from the trunk and hurried inside.
As soon as she was in her room, which surely hadn’t been updated since the early eighties, she pulled out her phone and called Emilie.
“Hey, girl. How’s Texas treating you?”
“Fine. Just feeling off balance.”
“Why?”
Hayden took a deep breath. If Emilie thought she was overthinking things, she’d know to relax. “I met a guard at a restaurant after his shift. He didn’t know much, but when I left I saw the director lurking in the parking lot.”
“Maybe he was eating there.”
“Then he wouldn’t hide by the Dumpster.”
“He could have just arrived.”
“I don’t think so. He was watching.”
A soft whoosh of air filled the line. “Need me to keep you company?” There was light teasing in Emilie’s voice, but Hayden also heard concern.
“No, I’m seeing a problem everywhere.” She paused, then plunged ahead. “Emilie, there’s only one hotel in town. What if I kicked a hornets’ nest?”
“Stay out of the way.”
Hayden smiled. “Gee, I didn’t think of that. Any tips for doing it?”
“Come home.”
“I can’t . . . not yet.”
Hayden quickly filled her in on what she’d seen and the deposition. “I didn’t get much. The director was adept at dodging questions.” She collapsed against the slim pillows. “Tell me about your day.”
They chatted for a few minutes, but Emilie still wouldn’t tell Hayden what her new story was about. “You’ll have to wait for the finished product.”
She’d always been that way, even in law school, refusing any help on her papers, even a proofreading. Her four A’s in Legal Research and Writing backed up the efficacy of her process.