“There it is,” Julie said, pointing to the left-hand side of the road.
In the middle of a large vacant tract was a long, white, single-story building with a crooked wooden cross in front and a hand-painted sign that read “Southside Church—R. Dabney, Overseer.” The church was larger than I’d imagined. Then I remembered Sonny Miller’s words that the ministry had prospered when Sister Dabney’s husband was on the scene. Next to the church was a small brick house with low shrubs in front. The paint on the wooden eaves was peeling. Apparently no one had been forced to paint in return for food or shoes.
Whatever buildings had been on the surrounding property were gone, leaving a few concrete slabs and several small piles of loose bricks. The church and house formed an island in the midst of property awaiting its future. Julie pulled into an auto parts store across the street.
“She could sell and move a couple of blocks to be nearer the people she’s serving,” I said.
“What?” Julie asked.
“Sister Dabney could relocate. I don’t know what Paulding offered to buy her out, but it wouldn’t take much money to build a smaller, more modern church that’s better designed for the outreach she’s doing. The congregation has dwindled since her husband ran off with another woman. Sister Dabney is more interested in providing help to homeless and poor people than running a dying church.”
“How do you know all this?”
“You can learn a lot if you get out of the air-conditioned car and start asking people questions,” I said, turning sideways. “Did one of those guys really pick up a rock and threaten you?”
“Let me see your notes.”
I opened my briefcase and handed her my legal pad.
“What happened to your checklist?” she asked.
“You would have run out of gas circling the block if I’d used it.”
I waited while Julie read. Her eyes opened wider.
“She used five homeless men as street preachers to stand on the corner near Paulding’s office and condemn him as a thief and sinner deserving of hell?”
“That’s the way I understand it.”
“That’s more bizarre than the facts on a law school exam.”
“Real people don’t always stay within the boundaries of a law professor’s imagination.”
Julie returned the notes to me. “Well, this backs up what the for-mer church member told you, only worse because Dabney took her hate outside the walls of the church. These drunks were her agents, and their actions clearly satisfy the requirements for slander—a false, malicious accusation of criminal conduct broadcast to the public at large with an intent to harm an identifiable person or persons.”
“How do you know it was false?”
Julie stared at me. “Is this your attempt at sick religious humor?”
“No, I’m thinking about Sister Dabney’s defense to the lawsuit. If she sincerely believes Paulding is going to be judged by God, does warning him make her conduct false or malicious? If so, hundreds of pastors could be sued for doing the exact same thing every Sunday morning.”
“You’re as nutty as she is. This is slander, pure and simple. My question is whether any jurors would award any damages to Paulding after they stop laughing at Sonny Miller and his band of drunken preachers. Mr. C and our client wouldn’t be happy if this ended up as a big joke.” Julie started the car’s engine. “I wish we could get a copy of the script Dabney gave them. Not letting the guys hand out flyers was a smart move. Without something to pin them down, I’d worry the drunks wouldn’t agree on what they said when they get on the witness stand. Let’s get out of here.”
“I think we should stay and see if she comes out of the house.”
Julie tightened her grip on the steering wheel. “Tami, you’re taking this investigation business too far. Mr. C didn’t send us on a stakeout.”
“Aren’t you curious to see her?”
“I’d rather let Dabney live in my imagination than meet her in person.”
“Then tell me the truth about the rock.”
“There wasn’t a rock,” Julie answered, putting the car in drive.
“But he was thinking about it. I could see it in his bloodshot eyes.”
AFTER WE RETURNED to the office, I typed up a summary of my interview with Sonny Miller and the brief conversation with Rusty Steele. I threw in my impressions of the church and ideas about possible resolution of the case. Julie and I spent the rest of the afternoon working on separate projects. Close to 5:00 p.m., Zach came into the library.
“Are you ready to give an update on the Paulding case?” he asked.
“Mr. Carpenter wants to meet with us in the conference room.”
“I thought he was going to wait until later in the week.”
“His schedule is his own. Bring your notes and come on.”
The three of us walked down the hallway.
Julie tugged on my arm and mouthed, “He’s still mad?”
I nodded grimly. The conference room was empty.
“I’ll let him know we’re ready,” Zach said.
In less than a minute, Zach returned with Mr. Carpenter.
“Hello, ladies,” the senior partner said.
Mr. Carpenter’s slightly effeminate tone wasn’t a sign of weakness; it was a velvet scabbard that concealed a sharp sword.
“I spoke with Jason Paulding about an hour ago. Dabney is aware that we’re documenting her attacks. She called Paulding personally and told him he’d better back off.”
“Did she threaten him?” Julie asked.
Mr. Carpenter referred to a legal pad.
“She told him that he would face God’s wrath if he attacked her, and read him a Bible verse: ‘Touch not my anointed, and do my prophets no harm.’”
“She can dish it out, but she can’t take it,” Julie said.
Mr. Carpenter looked at me. “I know the Bible is filled with allegorical references that can’t be interpreted literally. What do you make of this?”
I looked at Zach, who didn’t give any sign of helping.
“I’m not sure about allegory in the Bible,” I answered, “but that’s a passage from the Psalms warning the Jews to respect the prophets who speak on God’s behalf. It could also have a secondary meaning as a messianic reference since
Christ
and
Messiah
both mean ‘the anointed one.’ Jesus was the ultimate anointed prophet.”
“So Dabney believes she is a Messiah figure?”
My head jerked back. I hadn’t considered the possibility of such a great deception.
“Maybe, but I think it’s more likely she considers herself a prophet who shouldn’t be criticized.”
“Kind of like Judge Cannon,” Mr. Carpenter said with a chuckle.
The senior partner’s jokes weren’t funny, but Julie and I both manufactured a smile. Zach kept a straight face.
“And if she keeps talking, it’s going to make our case easier. Tell me what you’ve uncovered that has Dabney so stirred up.”
Julie went down the list of people she’d unsuccessfully tried to contact and ended with her conversation with Mr. McKenzie.
“I think he has a lot of promise related to a tortious interference with business or contractual relation claim,” she said, “especially if Paulding had to pay more for the same goods and services. That would prove financial injury.”
“But you don’t know,” Mr. Carpenter said.
“No, sir. We’re scheduled to meet with him tomorrow morning.”
“He’s a former client of the firm,” I added. “Zach is going to go with us.”
“Did you represent him?” Mr. Carpenter asked Zach.
“No, sir.”
“It was Ned Danforth,” I responded. “But it’s been awhile ago and it was only one case.”
“Anything else?” Mr. Carpenter asked Julie.
“No.”
“Let’s hear from you,” he said to me.
I omitted the messages I’d left for people who didn’t answer the phone and started with my conversation with Sonny Miller and Rusty Steele at Bacon’s Bargains.
Mr. Carpenter interrupted me as I explained what the protesters did.
“Jason mentioned this in our initial interview but didn’t give me details. He was out of town the day it took place, and he heard about it from his staff. Later a police officer identified a few of the men who were there.”
“Miller mentioned policemen were there.”
“What did the officers tell you?” Mr. Carpenter asked me.
“Nothing, yet. I tried to contact Officer Samuels, but that was before I interviewed Sonny Miller. Now I know what to ask him.”
“Do that as soon as possible, even if you have to track him down in his patrol car.”
“Also, I left a message for a reporter at the newspaper,” I said.
“She’s not on a newsbeat. She writes the weekend column for the Home and Garden section. Finally a former church member verified that Dabney spoke to the congregation about Mr. Paulding and accused him of criminal conduct.”
“Good.” Mr. Carpenter nodded. “That should be enough to support a slander action even without any evidence of economic damage.”
“But I still think Julie’s witness might be the best,” I replied.
“Saying a businessman is a thief doesn’t sound that bad. Last week I saw a man standing in front of a used-car lot holding a sign accusing the owner of ‘robbing him.’ Was that libel?”
Mr. Carpenter waved his hand. “The guy with the sign isn’t sit-ting on a valuable piece of property that our client needs. Get me in a courtroom in front of a jury, and I’ll convince them the value of a man’s reputation is worth a lot more than Dabney can pay. That’s all we need to get a judgment.”
“What next?” Zach asked.
“I want a complaint with a notice to take Dabney’s deposition attached to it on my desk by the end of the week. We’ll serve her, take her deposition, keep looking for more evidence, and amend the com-plaint to increase the number of allegations.” Mr. Carpenter pushed his palms together. “Winning a lawsuit is as much about maintaining pressure as it is proving facts. Attacking from multiple angles is key. Don’t let your opponent have any hope of relief short of surrender. Develop that reputation, and lawyers who see your name on pleadings will either refuse to take a case because they don’t want the hassle or advise their clients to settle quickly if they do.”
I’d taken a trial practice course in law school, but the professor emphasized courtroom decorum, not the psychology of war. Mr. Carpenter’s perspective made me doubt I’d ever be a trial lawyer. The senior partner looked at me and smiled.
“You’ve got that potential in you, Ms. Taylor,” he said. “I know where Bacon’s Bargains is located. Not many female law clerks would go there alone to interview witnesses like Miller and Steele. The absence of fear is the beginning of courage.”
“Julie was—”
“You’re right, Mr. Carpenter,” Julie cut in. “I’ve been calling her Tami the Tiger.”
I cut my eyes toward Julie. “No you haven’t.”
“Behind your back.”
“There’s no excuse for what this Dabney woman has done and is continuing to do,” Mr. Carpenter said, ignoring us. “Make sure there are requests for admission, interrogatories, and a request for production of documents served with the complaint.”
“Yes, sir,” Zach answered.
Mr. Carpenter continued. “Before she left, I asked Myra to double-check the real-estate records to confirm Dabney’s ownership of the property. She confirmed that Dabney’s husband deeded his one-half interest to her as part of a divorce settlement three years ago.”
“Did she have a lawyer in the divorce case?” Zach asked.
“No, the husband filed it pro se. She never answered the com-plaint, and the divorce sailed through. There’s not much to go on, but it looks like he decided to give her the church without a fight when he left town. There’s no security deed against the property, so she owns it free and clear.”
“Good,” Julie said.
“One other thing. Dabney contacted the minister at Paulding’s church the other day and made some defamatory comments to him.
The minister is willing to sign an affidavit, and Jason specifically wanted us to follow up with him. Nobody believes a minister in a court of law; they always support their parishioners. But it’s necessary to get something from him for client relations.”
“Tami and I will do that,” Julie said.
“One question,” I said. “What was the name of Dabney’s husband? The people I’ve talked to simply called him Preacher.”
Mr. Carpenter referred again to his legal pad.
“Fredrick Russell Dabney.”
My mouth went dry. “Is Ramona Dabney’s middle name Rachel?”
“No, it’s Rachel Ramona Dabney.”
“Anything else?” Mr. Carpenter asked.
I looked at Zach, who shook his head.
“Okay,” Mr. Carpenter said. “Let’s go to war.”
I WAS BURSTING TO TALK with Zach as we returned to the library, but when I caught his eye a second time, he put his finger to his lips.
“I can give you a ride home today,” he said.
I felt relief that maybe his anger toward me had lessened.
“Okay, thanks.”
“But that’s my time to bond with Tami,” Julie said, jumping in. “I’ve been taking her home all summer.”
“We definitely came unglued at Bacon’s Bargains.”
“Julie was there, too?” Zach asked.
“Yes and no.”
“Forgive and forget,” Julie answered. “That’s what you’re supposed to do. I can’t believe you were going to make me look bad in front of Mr. C.”
“I was only going to tell him that I wasn’t alone. I wouldn’t criticize you.”
Julie grabbed her purse and left.
“What are we going to do about Reverend Dabney?” I asked as soon as I was sure Julie had gone. “It has to be the same person Mr. Callahan mentioned.”
“Not here,” Zach said.
We walked in silence from the office and got into Zach’s car.
“Is the library bugged?” I asked. “Can we talk now?”
“No and yes. This isn’t Grisham’s firm in Memphis. But I need some time to figure out whether the connection between Dabney and Callahan makes a difference in our case. It’s been at least forty years since Mr. Callahan was around her. Our client’s problems developed within the past few months. If you’d blurted out something about Mr. Callahan in front of Mr. Carpenter, it would have taken him down a line of questioning we might not want to follow.”
“What do you mean?”
Zach pulled into traffic on Montgomery Street.