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Chapter 6 - The Trap of the Deposition

Eight days before the trial, Richard Latham struck back.

He served my mother with an emergency motion for an oral deposition. Under state civil rules, a defendant had the right to question the plaintiff under oath before the trial began.

The deposition took place on the fortieth floor of Latham’s corporate law firm downtown.

The conference room was magnificent and terrifying—a massive glass box overlooking the city skyline, featuring a twenty-foot polished mahogany table, plush leather chairs, and four camera operators recording every second for the official court record.

My mother sat on one side of the glass table. I sat right beside her, holding my cardboard folder.

Across from us sat Richard Latham, flanked by four senior litigation partners, two jury consultants, and Headmaster Victor Hale.

"State your full name for the record," Latham began, leaning back in his leather chair, a video camera pointed directly at my mother’s face.

"Lydia Marie Moore," my mother said, her voice steady.

For three agonizing hours, Latham hammered my mother with relentless, brutal questions. He asked about her past, her former jobs, her bank accounts, her late husband, her parenting choices, and her mental health. He rephrased the same questions twenty different ways, trying to trick her into contradicting her written statement.

"Ms. Moore," Latham said, his voice dripping with smooth, venomous sarcasm. "Isn't it true that you were disciplined twice at your previous job for failing to complete shift logs?"

"That was seven years ago, Mr. Latham," my mother replied calmly. "And it was resolved when the manager realized the logging machine was broken."

"Isn't it true that you suffer from anxiety?" Latham pressed, leaning forward, his eyes glaring through the lens of the camera. "Isn't it true that you have felt overwhelmed, stressed, and incapable of managing your daily life since your husband passed away?"

"Objection," I said, hitting my hand flat against the mahogany table.

Latham didn't even look at me. "The child cannot object during a formal deposition, Your Honor—oh wait, the judge isn't here, is he?" Latham snickered, looking at his fellow partners, who chuckled in unison. "Answer the question, Ms. Moore."

"The objection stands under Evidence Code 352," I said loudly, standing up and staring straight into the video camera lens. "Mr. Latham is engaging in badgering, character assassination, and introducing irrelevant personal medical history designed solely to harass the witness. If Mr. Latham continues this line of questioning, we will terminate this deposition immediately and request monetary sanctions from Judge Vance for bad-faith litigation tactics."

Latham’s smile vanished. He turned his head slowly toward me.

"You really think you're a real lawyer, don't you, little girl?" Latham sneered, dropping his pen onto the glass. "You think you can save your mother with library books and taped-together garbage?"

"I don't think I'm a real lawyer, Mr. Latham," I replied coolly, opening my cardboard folder and pulling out a single sheet of blue paper. "I'm just a daughter who knows how to read your firm's public SEC filings."

Latham frowned. "What are you talking about?"

"This morning at 8:00 AM," I said, placing the blue paper on the mahogany table, "the State Attorney General’s Office opened an official criminal tax fraud investigation into Crestwood Global Investments—the Cayman Islands shell company registered to your client, Victor Hale."

Victor Hale gasped, knocking his glass of water over, soaking his silk tie.

Latham looked at the blue paper. It was an official copy of the subpoena served to Crestwood’s bank accounts by the State Division of Financial Crimes.

"Where... where did you get this?" Latham stuttered, his slick composure shattering completely.

"I didn't get it," I smiled, leaning across the twenty-foot table. "Sarah Lin gave it to the Attorney General yesterday. And guess who they named as a co-conspirator for organizing the illegal transfer of funds?"

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I pointed my small finger straight at Richard Latham’s chest.

"You, Mr. Latham. Page four, line twelve. Your law firm processed the offshore transactions."

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