Noa (October)
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Foxfire, Esq. | Chapter Thirteen
🕑 Added 2025-01-14 04:46:29 +0000 UTC[Content Warning — racism & general, nonspecific bigotry]
Three months had passed since that day in the conference room, since the moment Destiny Banks crushed the defendants’ hopes of a quick, if costly, settlement.
Throughout those three months, I’d sat down with Julio and Fatima on almost every Thursday at 3:15pm, ensuring all three of us were on hand for check-in calls with Mrs. Banks. We kept her apprised and up to date on everything that had happened, what we’d gotten in from opposing counsel, what kind of BS they looked liable to try and pull, what if anything she needed to do here, etcetera. On some weeks, the call lasted maybe ten minutes, and amounted to little more than having Mrs. Banks call the Judge’s chambers and complain that the defendants weren’t cooperating with her lawyers. On other weeks, that call lasted a good hour and a half, complete with me spelling out exactly what the information we’d received meant for her case, and what she’d need to be ready for because of it.
And then there were the exception weeks: the ones where we didn’t need to have a phone conference, because something about the case mandated that we meet in person, or that she be present for things.
This fine, brisk week in October was one of those weeks. Friday, October 15 was one of those days.
And we hadn’t had a phone call with Mrs. Banks yesterday because she was here with us today, in one of the conference rooms at the firm, to observe the deposition of the property manager tasked with overseeing the apartment building, a Mrs. Leslie King.
The stenographer had gotten in early and was all set with an e-reader, fully expecting the deponent to be late. The rest of us were all ready in the conference room and seated with our backs to the door for when Mrs. King and her lawyer arrived: Julio and Fatima on my right, Mrs. Banks on my left, and the welcome addition of Mr. Miguel Arroyo accompanied by DCHA’s attorney advisor, Mr. Jason Wilbourne. As we had learned at Mr. Arroyo’s deposition, the poor building inspector had been under pressure from WCS & Co. to regularly renew their approval with minimal inspections. Oh, sure, that expectation hadn’t ever been explicitly said by anybody, and especially not put to writing.
But the property manager had always taken the time out of her busy, busy day to meet Mr. Arroyo out front before an inspection, and always asked how his sister and nieces were doing.
His sister and nieces who lived in another property owned by WCS & Co., which was also managed by none other than Mrs. Leslie King.
Now, that was more than enough to arouse suspicions and give us enough grounds to have the property management company free up her schedule for a deposition. But we’d gotten this on the books a week ago. That was plenty of time for due diligence on our part, such as reviewing the documents we’d received from Mrs. King’s employers.
And, oh, the things we’d discovered.
One of the secretaries knocked on the door to the conference room, and I stood to face the door. On my instructions, however, nobody else did. They all stared straight ahead, backs to the door, and studiously ignored everything that was about to go on behind them.
“Enter,” I called.
The secretary, a young Vietnamese woman named Linh, who’d only started working for us recently (and who had already left a very good impression by just being kind when she had nothing to gain from it), met my eyes before holding the door open for the deponent and her attorneys. As they entered the room, I briefly glanced at Linh, whose expression of suppressed distaste was all I needed to know what to expect.
“Good afternoon,” I said as I met the gaze of my opposing number for the day: an older man in a pinstriped suit. “Is your client ready to proceed?”
“Oh, don’t you worry your pretty little head about me, darling, I’m all set whenever you’re ready.”
I flicked an ear in annoyance, mirroring the annoyed twitch of Pinstripe Suit’s eye, and turned to look at the deponent herself.
Mrs. Leslie King was an older white woman who seemed to think that emulating the air and appearance of a younger Betty White would be enough to make people overlook any other details about her. Every single bit of her appearance was aggressively inoffensive, as odd as that combination of words might seem: muted colors, cozy fabrics, and styles that were already dated well before the turn of the millennium. This woman’s everything was Crate and Barrel by way of the Easter Bunny, and it all seemed too deliberate to be genuine.
The way the skin around her watery blue eyes seemed to tighten once she’d gotten a good look at me only reinforced this expression. Like I’d said before, there were three main reactions I tended to get from people who saw me for the first time: confused utterance, muted disgust, or shocked silence.
With the way this woman’s appearance was so carefully crafted to give the impression that butter wouldn’t melt in her mouth? Yeah, muted disgust was a given.
I looked away from Little Miss Cottagecore and locked eyes with her lead attorney.
“Counsel, please advise your client that until she is under oath and the deposition is underway, we are not to address one another directly.”
“Oh come now darling, you don’t gotta be bitchy about little old me,” Leslie King said with a smile that lied about as well as the rest of her aesthetic.
… I wanted to strangle her. Bitchy? Bitchy!? I was not a dog! I was part canid, yes, but I was not some simple canine! I was a wonderful, mischievous, fluffy fox, not some dime-a-dozen puppy mill output!
Plus, that little Southern Belle affectation of hers that she’d so clearly kludged together from who knows how many little slices of Americana? And the way her lips came together with a loud, wet smacking sound due to how heavily she’d applied her lipstick? And the jingle of far too many keys hanging from a keyring on a brand new Louis Vuitton purse?
Ooh, I’d only just met this woman, but she already made me so, damn, mad! God, how did Mrs. Banks stand interacting with this, this… urgh! No, no, Naomi, don’t lose your temper on this insignificant little twit, she was not worth it, you’d have plenty of time to make her regret those comments, just… deep breaths.
I chose not to actually say anything else as a response. Instead, I just held the door open for them, and sat down in my chair once they’d made their way to the other side of the table.
Then, once we were all set, the stenographer took over briefly. All of us repeated our full names, and relationship to each party — Julio, Fatima and I were Mrs. Banks’ attorneys; Mr. Wilbourne was representing Miguel Arroyo; some stooges named Kevin Cole and Mitch Goodson were representing Property Management Solutions, Inc. and the property manager for the building that had burned down.
And then, the ball was back in my court.
“Mrs. King, I am Naomi Ziegler, an attorney representing the plaintiff, Mrs. Destiny Banks. This is a deposition, in which I will ask you questions and you must answer them truthfully unless your attorney tells you clearly and directly not to answer. Although no judge is present, this is a formal legal proceeding just like testifying in court, and you are under the same legal obligation to tell the truth, the whole truth, and nothing but the truth. If you do not understand any of my questions, feel free to say so, and I will rephrase it. Before the deposition can be used in court, you will have the opportunity to read over it and correct any mistakes. Do you understand this?"
“Why yes I do, lil’ miss!” Mrs. King gave me another one of those insincere smiles of hers, and it was a trial to not give that the snarl it deserved.
“Very well.” I extended a hand to the side, and Julio dutifully handed me the legal pad full of pre-depo notes he’d gone and written up. It was time to begin the plan.
That said… before I get too far ahead of myself: depositions.
For the most part, these are exactly like testifying in open court. You are placed under oath, meaning that everything you say is under penalty of perjury, but as per usual, perjury is quite hard to prove, particularly in regards to opinion testimony. A lawyer asks you questions, and you have to answer them. If you try to get evasive, the lawyer gets to put you to the screws for as long as they have you. A court reporter transcribes the entire thing, and produces a transcript at the end of the day with everything said — and no matter what you do, do not try to trip up the court reporter by talking too fast. It doesn't work. It literally never works. We all bring dictaphones, and if somebody starts playing that game, we turn them on to record everything.
Now, there were a handful of psychological tactics in depositions. One of them was to always make sure the deponent is facing both you and the door at the same time. This sets you up as a gatekeeper of sorts — if they want to leave, they must get past you. And you didn’t just want to ask them question after question, drawing out that captivity for as long as possible. You also wanted to lead them in circles, until they’d answered the same question enough times that contradictions could start piling up.
But sometimes, like here, there was no need to go that far. All you had to do was get your research done ahead of time, show up prepared, and wait for them to fall into your trap.
“Mrs. King, you are an employee of Property Management Solutions, Inc. How long have you been working for this company?”
“Oh, going on twenty-five years now!” Mrs. King accompanied the answer with a simpering little giggle, the sort that held no real humor in it.
“And how long have you been acting in your position as property manager?”
“Hmm, thirteen? Oh, no, this was after that dreadful storm down south. Fourteen years!”
“And what apartment buildings do you serve as property manager for?” I asked as a follow up.
“... I, I’m sorry darling, I don’t quite recall all of ‘em.” Her apologetic smile was less forced than the rest, but there was a certain smugness to it.
“Oh no, that’s okay!” I held up the pre-depo notepad Julio had handed me. “I have a list of them all right here. How about I just read them off and you tell me if I’ve got them all.”
“Objection,” one of her attorneys said, the one in pinstripes. I already couldn’t remember whether he was mister monosyllable or the one whose name was wishful thinking, and frankly, I didn’t care.
“So noted!” I said, false cheer in my voice. “Alright Mrs. King, I’m going to start reading off the list, please forgive me for not being in alphabetical order. Let’s see… Marigold Residences?”
“Yes, that’s one of them,” she said.
“Objection.”
“Marigold Courtyard?”
“That is too.”
“Objection.”
“Marigold Apartments?” I asked, watching her expression.
“And that one,” she said.
“Objection.”
“Marigold Terrace?”
And on it went like that, with me reading off a good seventeen names.
So, to prevent confusion: anybody who had ever seen a trial would notice that the objections weren’t stopping me. That was because, for the most part, objecting didn’t actually do anything during the deposition itself.
See, when you lodged an objection, the stenographer recorded it. If that witness later got called to testify in court, the attorney only got to reiterate the same objections they’d already made, but actually had to argue them this time. If there was a question they wanted to object to in court, but hadn’t done so during the deposition? Well tough shit, no objection for you.
That said, there were two main exceptions. The first one was the work-product exception — you couldn’t ask a deponent about, say, the kind of stuff they talked about with their lawyers. The second exception was if you were using the deposition to harass the other person. Had I been on the receiving end of this? Yes. Had I ever done it to somebody else?
Well…
“Okay, Mrs. King,” I began, once I’d ticked off every name on my list. “That makes thirteen separate buildings you say you were the property manager for?”
“That is correct,” she said.
“Ma’am, are you aware that you answered ‘yes’ to having been the property manager for fourteen different buildings?”
The expression of sheer shock on her face was almost worth the insult she’d handed me earlier.
“Objection!”
“Let’s see, it was the… seventh building I named.” I glanced down at the notes. “Flats 230. You don’t manage that building, do you? In fact, it doesn’t even exist, does it?”
“Objection,” Pinstripes said, waving for his client to remain silent as he stood. “Counsel, this is an abuse of the discovery process to harass my client, and you know it. Ma’am, don’t answer that question.”
“Well, see, that’s all fine and dandy,” I said, leaning forward as I let my lips spread into a mean smirk of my own. “But the fact remains that your client has a few questions she still needs to answer. Is she aware that, while under oath, she attested to having been the property manager for thirteen buildings at the time of the incident, but also agreed that she was the property manager for fourteen separate buildings, with each one being named separately?”
I heard an amused huff off to the side, and I knew without having to look that it was Miguel Arroyo. He was the one who’d given us the list of properties Leslie King managed, because she always made sure he was the one scheduled to visit them.
“I… I am aware of that,” Mrs. King said. All of the smugness she’d had on walking into the conference room was long gone. Her posture had gone from loose and relaxed to something guarded, compacted in on itself. Her upper arms were pressed tight against her sides, hands clenched tightly onto her overpriced designer purse.
Her eyes flicked up towards me, then past me to the door. I swiveled my ears a bit, drawing her attention away from the door, and then lowered them to direct her attention back to my smirk, which she ever so slightly flinched away from.
She thought I’d been bitchy before, had she? Had she perhaps thought herself the hound to my fox, hmm?
Well, that illusion was long gone.
“So which one was it?” I asked. “Thirteen buildings, or fourteen?”
“Thirteen,” she confirmed. “Yes, I’m very certain.”
“I see, thank you.” I flipped the page on the legal pad. “Now, how often did you work on-site at the various properties you manage?”
“Well, it depends on the property, of course!” Her tone was an odd thing, simultaneously sounding like begging even as she tried to talk down to me. This was also clearly a question she’d been prepped for, given how much of a non-answer it was.
“Per month, then.”
“Well, at least once a month per property, certainly,” Mrs. King asserted. “Can’t go too long without stopping in and bringing marching orders from head office, don’t you know.”
“Now as you know, my client used to live in one of the properties you managed before it burned down,” I continued. “So I have to ask: if you were regularly stopping in at each property at least once a month, when in the month of December did you ‘bring marching orders from head office’ to the Hillside Terrace?”
“I, I’m afraid I don’t quite recall,” Leslie King waffled.
“And what about in November?” I asked.
“W-well, it would’ve had to be before Thanksgiving, the whole family went down to Georgia to surprise my youngest for the holiday.”
“Mrs. King, can you name even one date that you set foot on the Hillside Terrace property?”
“Yes I damn well can!” Leslie King asserted, shaking enough to set the too many keys on her overpriced purse jingling. “Day before Halloween, I judged the building costume contest and they called me Elpheba when I didn’t give the win to the worst Dorothy I’ve ever seen!”
“I see, I see.” I reached under the notepad and pulled out a sheaf of documents. “Reporter, please log these documents collectively as plaintiff’s exhibit number 73, lease documents, and let the record reflect that I’ve provided a copy to opposing counsel.” I stood up, handed one copy of the packet to the stenographer, and another copy to Pinstripes before going back to my seat.
“It’s been marked,” the stenographer said.
“Thank you,” I said, and she offered a small half-smile in response. “Mrs. King, do you know what the packet of documents in front of you is?”
“Lemme see…” Leslie flipped through the papers, the worry on her face fading away to boredom as she appeared to recognize what she saw. “These’re lease documents. We have copies of ‘em in the head office and in each building’s office.”
“Yes,” I said. “Now, take a look at the bottom of page 34. Whose signature is that on the lease?”
“It says it was signed by Destiny Irene Banks.”
“And you are aware that Mrs. Banks is in the room with us today?”
“Well of course, she’s sitting right there next to you!” she exclaimed.
“Mhmm. Now, do me a favor.” I motioned with my hand. “Flip back to the first page for me, and read off the name of the apartment building that this lease is for?”
“Let’s see here, it says…”
I saw the instant realization hit her. A fun set of emotions flickered across Leslie King’s face: confusion, then disbelief, followed by anger, before finally settling on sheer dread. The way the blood drained from her face was an absolute sight to behold.
She looked back up at me, and immediately looked away from the predatory grin I’d allowed to grace my visage.
“Well?” I asked, teasing the answer out of her. “We’re waiting, Mrs. King.”
“Objection,” Pinstripes lodged. Mrs. King initially looked up in hope that she might not need to answer, but then her attorney’s fight left him the instant my attention fell on him, and with it, any hope of her getting out of this.
“It…” She gulped. “I-it says ‘Hillside Courtyard’.”
“Mrs. King.” I treated her now to the deepest frown of disappointment I could manage, complete with pulling my ears low and back. She apparently did recognize that bit of body language, if the way she shrunk away from me was any indication. “Hillside Courtyard burned to the ground on December 27, 2019. From the way you were speaking just now, you couldn’t tell the difference between two properties you managed: one that still existed, and one that hasn’t for most of a year.
“So I’m going to ask again: referring specifically to the building that no longer exists, when was the last time you so much as set one foot in the building?”
“I…” Leslie King looked past me again, to the door I sat in front of. “I don’t recall.”
“I see, I see,” I said.
I jotted down a quick note to remind myself to come back here in, oh, two hours. Then I reached out a hand toward Fatima, who handed me an even thicker trio of packets than the ones I’d already distributed.
“Reporter, please log these documents collectively as plaintiff’s exhibit number 74, ‘Collected Complaints to the Hillside Courtyard Management Office’, and let the record reflect that I’ve provided a copy to opposing counsel.” Once again I passed out copies to the others, and once more I resumed my vigil over the door.
“So marked.”
By the time I returned to my seat, Mrs. King was already flipping through the packet, and the longer she paged through them, the less color remained in her complexion. The skin on her neck and ears was practically an ashy gray, making the layers of foundation and concealer she wore stand out rather painfully.
“Mrs. King, as you can see, the document before you is a collection of the complaints sent by former Hillside Courtyard residents to your office and email address.” I tapped my own copy of the packet. “Now, let’s go through complaints and address them one by one, shall we?”
Leslie King took one last look at the door behind me before resignation fell like a curtain across her face.
Oh, yes, honey. You were never the hound to my fox. You were only ever a scared little rabbit, desperately trying to hide from my hunt. For the next six hours, I was going to make this tasty little morsel squeal.
And I would enjoy every single second of it…
Comments
Walrus
Look that shouldn't be attractive Naomi why is you being blood thirsty attractive...
Tsume Eiranis
First of all... I am sorry that you had to, and most likely still have to, deal with such people. Thank you for the chapter, excellent writing, feels a bit like catharsis, too.
