Betrayed (Rosato & DiNunzio, #2)(53)
Judy checked the notes in the file in front of her, but they were on a different subject. “Uh, let me see, the regional manager who oversees fifteen branches in the Philadelphia Metro Region is Mr. Guy Morrell. Is that correct?”
“Yes.”
“Where is his office?”
“Center City.”
Judy’s eyes strayed to her phone, wishing her mother could text, at least. She didn’t take notes, so she could help Govinda forget it was a legal proceeding, but she was having a harder time than usual listening. “Mr. Govinda, let’s shift gears. As a financial sales consultant, what were Ms. Adler’s job responsibilities?”
Kelin interrupted, “If you know.”
Govinda nodded. “Linda was supposed to sell investment and traditional banking products to our customers, including checking accounts, savings accounts, credit cards, and loans.”
Judy made a mental note that he used her client’s first name. “Are you aware that as a financial sales consultant, Ms. Adler had a quota of minimum monthly production goals to meet?”
“Yes.”
“Her monthly investment production goal was $1,000 and her minimum revenue requirements were sixty thousand minimum revenue credits. Is that correct?”
“Yes.”
“And she received incentive pay as well, did she not, for meeting those quotas?”
“Yes.”
Kelin sighed, still gazing out the window. “I’m not bothering to object, but is this line of questioning necessary, Judy? You can confirm it from her personnel file.”
Judy knew it wasn’t objectionable. “I’m trying to understand how much about Ms. Adler’s performance Mr. Govinda knows, and the only way to do that is to ask him.” Judy turned to Govinda. “To the best of your knowledge, did Ms. Adler meet those minimums every month of this year?”
“Yes.”
“How about the two previous years she’s been employed by Penn Bank?”
“Yes.”
“To whom does Ms. Adler report?”
“To the regional manager, Mr. Morrell.”
“To whom do you report?”
“I also report to Mr. Morrell.”
“How is it that you have information regarding whether she meets her minimum revenue goals or not?”
“She told me, uh, us, at lunch.”
“And was it part of Linda Adler’s job to refer clients to you?”
“Yes. She wasn’t licensed to sell investments over $100,000 and she referred those clients to me.”
“How many such clients has she referred to you this year, to date?”
“Sixteen.”
“How many of those resulted in closed sales?”
“Sixteen.”
“And the year before that?”
“Fifteen.”
“How many of those resulted in closed sales?”
“Fourteen.”
Judy skipped ahead, growing impatient and edgy. “Mr. Govinda, does the fact that you were able to close the sales reflect on Ms. Adler in any way?”
“Yes. She cultivated high-quality targets.”
“Do you know how she did that?”
“Yes, through cold calls and a network in the community.”
“What was Ms. Adler’s network, to which you just referred?”
“She belongs to Curves and she’s in a few book clubs. One of our customers came from her book club and another from church. They were high-net-worth individuals and I was able to close the sale with them.”
“Do the four other financial sales consultants in the Philadelphia Metro Region refer clients to you?”
“Yes.”
“Did any of them send you as many referrals as Ms. Adler did?”
“No.”
Judy knew she should ask for the details to lay her brick foundation, but she couldn’t fight her anger at him, at the injustice to Linda Adler, at Bennie, at the hidden money, and even at breast cancer. “Do you believe that Ms. Adler deserved the promotion to branch manager?”
“Objection!” Kelin swiveled his neat head around, with a new frown. “It’s irrelevant whether or not the witness believed Ms. Adler was entitled to the promotion.”
Judy felt herself losing her temper. “No it isn’t, and we both know that relevance isn’t a proper objection at deposition. Mr. Govinda, you may answer the question.”
Kelin snorted. “Don’t answer, Devi. I’m instructing you not to answer.”
Judy reached into the middle of the table and snatched the telephone receiver from its cradle. “Rick, shall I call the judge right now and get a ruling? You tell me.”
“Fine, that won’t be necessary.” Kelin rolled his eyes. “Mr. Govinda, you may answer the question. I’ll note for the record that this is Mr. Govinda’s opinion only.”
Judy faced Govinda, trying to get in control. “Mr. Govinda, did you think Ms. Adler deserved that promotion?”
“It’s not for me to say,” Govinda answered, his expression impassive.
“It is now,” Judy shot back, and Allegra looked over, her fair skin flushing. “Mr. Govinda, I’m asking you a question, and you are compelled to answer. In your opinion, didn’t Ms. Adler deserve that promotion?”