Betrayed (Rosato & DiNunzio, #2)(51)

“Judy? You were saying?”

“I just sent you an email that lists all seventy-five new matters.”

“Wow! Seventy-five!” Allegra’s pale blue eyes lit up behind her glasses, and Judy wished she could share the intern’s enthusiasm.

“Print the email, open the boxes, and use it as a checklist.” Judy checked her laptop screen, momentarily distracted by the sight of her other email piling onto her monitor screen by the dozen, making a hill she could never climb. She flashed on Bennie’s telling her last night that she didn’t have a client base. It was true, but today it seemed beside the point, because she sure had tons of work.

“Then what?”

“Then—” Judy looked up from her laptop to see that Allegra wasn’t taking any notes. “How are you going to remember this?”

“I’ll remember.”

Judy let it go. Allegra was allegedly a Girl Genius, but it was still a little hard to believe. “Make sure we have each of the files.”

“Then what do you want me to do, once I see if all the files are there?”

“We’ll have to organize them.” Judy slid her phone from her purse and placed it on the desk, so she wouldn’t miss a call from her mother at the hospital.

“How? Alphabetically by plaintiff? By date of complaint? By trial date?”

“I’m not sure yet.” Judy’s brain was too busy to deal with Allegra’s excellent questions and/or youthful enthusiasm right now. “I’ve never run litigation this extensive. You’ll probably be in college by the time we’re finished trying those cases.”

“I’m already in college.”

“What?”

“I take college courses, at Penn State’s branch campus.” Allegra grinned. “Anyway, can I come to the deposition? Bennie said it would be good if I did. That’s why I dressed up.”

“All right,” Judy said, though she was getting tired of Bennie running her practice.

“Yay! What do I do?”

“Just sit quietly and take notes, or act like you’re taking notes. Be unobtrusive. If they object to your being there, I’ll have to ask you to leave. Only parties and counsel are permitted at depositions, but I’m going to pass you off as a paralegal.”

“I can act like a paralegal. Hard-working and underpaid. Same as an intern.”

Judy smiled, for the first time that day. “Have you ever been to a deposition before?”

“Yes, with Mary, but she was defending it, not taking it.”

“It’s a very different purpose.” Judy got up, went to her credenza, and pulled out the case file while she spoke. “When you take a deposition, the purpose is to find out as much as you can from the witness, so you’re prepared for anything he says on the stand at trial. This is going to be boring, I’m afraid.”

“That’s okay. I like to learn.”

“Good. This is just a step in the process, the beginning of the exercise in delayed gratification that’s the life of the trial lawyer.”

“Okay.”

“What that means in practical terms is that I want the witness to relax at the deposition. I’m going to ask open-ended questions. I’m going to let him yap. I’m not going to cross-examine him, like at trial. No pyrotechnics. No Law & Order.” Judy found the case file in the drawer, slid it out, and let the drawer roll closed. “It’ll be like watching someone lay bricks, one by one. I’m building a foundation for a case at trial. You understand?”

“Yes.”

“So if I act nice to him, don’t be fooled. On the stand, I’m going to make him wish he’d never met me.”

“Whoa,” Allegra said, her eyes glittering. “It’s Dark Judy.”

“Right.” Judy did feel bile course through her system, but maybe because she had so much on her mind lately, like Aunt Barb, Iris, and her mother. And Frank, who’d left the apartment last night with barely a peck on the cheek. “But not today. Today will be a snoozefest. His lawyer, who’s good, will try to stop him from talking. They will have met before the deposition, and his lawyer will have told him not to volunteer, answer only the question asked, and keep his answers to yes or no. This matters a lot in this case, because it hinges entirely on a credibility question.”

“What’s the credibility question?”

“This is a sex-discrimination case, and our client is Linda Adler, a financial consultant at PennBank, who says she didn’t get a promotion to branch manager because she’s a woman. The reason she thinks that it was discrimination is that she heard that her boss said to the witness, ‘there’s no room for women at the top at PennBank.’”

“That’s terrible!” Allegra’s slim hand flew to her mouth, and Judy noticed her fingernails were bitten down.

“It happens, still.” Judy closed the lid of her laptop, to take it with her, like a security blanket for grown-ups. “The witness today is Devi Govinda. He wasn’t the one who made the statement, that’s his boss Guy Morrell, but I’m saving Morrell for the last deposition.”

“Why?”

“I want to get as much information as I can before I meet Morrell, because he’s the person who decided not to promote Linda.” Judy slid her notes from the case file and skimmed them quickly while she spoke. “The only fact we have against us is that some of the comments in Linda’s employment reviews aren’t stellar, so the company is claiming that’s the reason they didn’t promote her. She doesn’t believe that that’s the real reason and I don’t either, but under the law, I have to prove that it’s a pretext.”