Irrefutable Evidence (6 page)

CHAPTER TWELVE

Laura
’
s hands were shaking, so she kept them clasped tightly together in her lap under the dark mahogany table and hoped the lawyer couldn
’
t see. She surveyed the conference room
—
shelves and shelves of leather-bound books with gilt lettering. She wondered if anyone actually used them. They seemed to have acquired a thin coating of dust. Her eyes returned to Attorney Chadwick. He sat across the table watching her, appraising her. She wet her lips and forced a smile. She didn
’
t know why she was so nervous
—
he represented the company, he was on
her
side.

He leaned his pointy little chin forward and squinted at her as though he
’
d read her mind somehow.

“
Now, listen, Laura
—
may I call you Laura?
”

“
Sure.
”

“
Thanks, and you go ahead and call me Phillip.
”
He smiled reassuringly then continued,
“
I don’
t want you to fret about this deposition tomorrow. You hear? It
’
s my job to prepare you for the questions I think the lawyer is going to ask you. You
’
ve got the easy part. You just have to listen to me and pay close attention. If you do that, when you walk out of here today, you
’
ll be more than ready for whatever she throws at you. Got it?
”

“
Yes.
”

“
Now, I bet you
’
re thinking how
’
s this joker know what Sasha McCandless is going to ask me? Is he psychic? And the answer is no, I
’
m not psychic, but I
’
ve been doing this for a very long time, Laura. I probably know the questions she
’
s going to ask better than she does at this point. But if she comes out of left field with something we haven
’
t covered or a trick question, I
’
ll jump in and protect you.
”

She gnawed at her lip. His little pep talk had just begun to ease her fears but the whole
trick question
bit got her stomach churning again.

“
Um, what do you mean by trick question? All I have to do is tell her the whole truth. Right?
”

He chuckled at that and shook his head.
“
Oh, Laura, you
’
re going to be a problem child, eh? No. All you have to do is answer the precise question she asks you if, and only if, you
’
re sure you know the answer and remember it correctly.
”

“
Isn
’
t that the same thing?
”

The last vestiges of his smile vanished from his face.
“
No. Not in the least.
”
He spoke in a firm, disapproving voice as if she were a misbehaving puppy.

“
Oh, sorry.
”
She stared down at her reflection in the highly polished tabletop.

“
Now, now, there
’
s no need to apologize,
”
he said mildly.
“
Let
’
s start over, huh?
”

She glanced up at the sudden change in his tone and was surprised to see that he
’
d pasted his smile back on his face.

“
Sure,
”
she agreed eagerly.

He cleared his throat and thought for a moment before launching into his lecture. She stared at him attentively, willing herself to pay close attention so she wouldn
’
t screw up at the deposition.

“
It
’
s like this. The other attorney, she wants you to think you
’
re having a friendly conversation. She
’
ll try to establish a rapport with you, get you in rhythm, and suddenly it
’
s like you
’
re telling her a story, just talking conversationally. Don
’
t fall for that. She
’
s not your friend. She
’
s the enemy. The only answers I want to hear come out of your mouth tomorrow are
yes, no, I don
’
t know, I don
’
t remember,
and
I don’
t understand the question.
Got it?
”

She nodded.

“
What are the acceptable answers?
”
he prompted.

“
Uh, yes, no, I don
’
t know, I don
’
t recall, and I don
’
t understand?
”

“
Perfect.
”

She exhaled shakily and relief washed over her.
“
Can I write that down?
”
she asked as she reached into her bag for a pen and notepad.

“
I
’
d rather you didn
’
t. At the beginning of the deposition, she
’
s going to ask you a bunch of seemingly innocuous questions, they
’
ll seem almost like background. But remember this: there are no innocent, throwaway questions in a deposition.
”

“
Okay.
”

“
One of those questions will be whether you and I met to go over your testimony. She
’
ll ask if you took any notes and, if so, whether you have those notes on you. The answer needs to be no, no notes. You
’
ll tell her we met briefly to review the topics covered by the deposition notice. Tomorrow, when you show up in her office for the deposition, bring nothing
—
no documents, no notes, no datebook or calendar. Nothing. Understand?
”

“
Yes.
”

“
Okay. Now, when are you heading to Pittsburgh?
”

“
I
’
m on the 6:30 flight through Philly.
”

“
Good. Go to the hotel, eat dinner, and go to sleep early. No booze, no heavy foods. I want you to be bright eyed and bushy tailed tomorrow morning. Understand?
”

“
Yes.
”

“
Now what are your answers, one more time?
”

“
Yes. No. I don
’
t know. I don
’
t remember. I don
’
t understand.
”
She ticked them off on her fingers as she recited them.

“
Perfect. Let
’
s turn to the notice.
”
He flipped to the second page of the deposition notice and patted the top of a white three-ring binder, thick with documents. It had to be five inches thick. An identical binder sat beside it.
“
Now, these documents are the ones we gave the Maravaches
’
lawyers in response to the document request. A lot of them
—
most of them
—
came out of your claims file.
”

She eyed the stacks.

“
You don
’
t expect me to have them memorized.
”

He didn
’
t respond.

Her pulse fluttered.
“
Do you?
”

He laughed.
“
No, of course not. But, just out of curiosity, how many of them do you think you could speak about intelligently without our going over them
—
ballpark?
”

She thought.
“
One hundred percent of the documents from my files. And anything related to the overall denial/payment statistics for the past, oh, four or so years. I can
’
t make any promises beyond that.
”

His eyes bulged out.
“
Are you serious?
”

“
Yes.
”

“
How is that possible?
”

“
Well, I have to have a good understanding of the facts underlying my own claims, obviously.
”

“
And the rest?
”

Come on, Counselor. The single Asian woman is the obvious choice for a thankless, numbers-intensive extra chore to be completed outside of her scheduled work hours,
Laura thought. But she pushed the grim truth aside and parroted the language from her annual performance evaluation.

“
My facility with statistics makes me uniquely suited to spearhead a department-wide analysis of decisions. So I
’
m tasked with performing one on a yearly basis.
”

He grimaced.
“
You get the crap sandwich, huh?
”

“
Something like that.
”
She tried to suppress her smile. Maybe Phillip Chadwick wasn
’
t so horrible after all.

“
That sounds terrible, but I have to say it pleases me that you can address this pile of stuff without our going over the documents. For one thing, it
’
s always great to have a witness who doesn
’
t seem coached. If you know this stuff cold, that
’
s perfect. And for another, pardon my French, but it
’
s as boring as watching piss dry.
”

“
Uh, you mean paint?
”

“
Nah. Watching paint dry would be a real party compared to walking through these policy riders and stuff.
”

Laura
’
s stomach picked that particular moment to growl
—
a loud, long sound that seemed to echo off the book collection and reverberate in the quiet room.

He burst into laughter then checked his watch.
“
Eh, I bet you skipped lunch to prepare for this, huh?
”

“
Guilty as charged.
”

“
Go get a snack and then get yourself to the airport. We don
’
t need to worry about the rest of this.
”

Her anxiety about the upcoming deposition far outweighed her desire for a sandwich.
“
But
…
we haven
’
t gone over anything. I don
’
t know what sort of questions she
’
s going to ask. Please. I
’
ve never been deposed before.
”

She pinned him with a desperate, pleading look.

He sighed heavily and checked his watch.
“Two o’clock. I guess we have time.
Well, it was worth a shot.
”
He dragged the top binder over to him and opened it. The hard plastic cover slapped against the table.
“
Let
’
s get this over with.
”

~ ~ ~ ~ ~ ~ ~ ~ ~ ~

Laura stifled a yawn and leaned against the elevator car
’
s railing. She was stiff and achy
—
like she
’
d run a 10K or spent a whole day painting her living room. She never would have thought sitting in a leather chair looking at pieces of paper could be so physically demanding. Mentally draining, sure. But she was exhausted. She
’
d wished she could drag herself home and crawl into bed.

But no. Her flight departed in one hundred and fourteen minutes. She had just enough time to drive to the airport, park in the cheapest, furthest lot (the only one Mid-Atlantic would reimburse her for), clear security, and scarf down an overpriced, underflavored sandwich before boarding the plane for the short trip to Pittsburgh via Philadelphia.