"To Tillman Gantry?"
Lam froze, and closed his eyes to ponder the question. "Who?" he asked.
"Who owned the warehouse?"
"I paid rent to some dude named Johnny."
"Who did Johnny work for?"
"Don't know. Don't care. Didn't ask."
"How long did you live there?"
"'Bout four months."
"Why did you leave?"
"Who evicted you?"
"I don't know. The cops showed up one day with some other dudes. They yanked us and threw us on the sidewalk. Couple of days later, they bulldozed the warehouse."
"Did you explain to the cops that you were paying rent to live there?"
"A lot of people were saying that. This one woman with little kids tried to fight with the police, but didn't do no good. Me, I don't fight with cops. It was a bad scene, man."
"Were you given any paperwork before the eviction?"
"Any notice to get out?"
"No. Nothing. They just showed up."
"Nothing in writing?"
"Nothing. Cops said we were just squatters; had to get out right then."
"So you moved in last fall, sometime around October."
"Something like that."
"How did you find the place?"
"I don't know. Somebody said they were renting little apartments in the warehouse. Cheap rent, you know. So I went over to check it out. They were putting up some boards and walls and things. There was a roof up there, a toilet not far away, running water. It wasn't a bad deal."
"So you moved in?"
"Did you sign a lease?"
"No. Dude told me that the apartment was illegal, so nothing was in writing. Told me to say I was squatting in case anybody asked."
"And he wanted cash?"
"Did you pay every month?"
"Tried to. He came around on the fifteenth to collect."
"Were you behind on your rent when you were evicted?"
"Maybe one month."
"Was that the reason you were evicted?"
"I don't know. They didn't give no reason. They just evicted everybody, all at once."
"Did you know the other people in the warehouse?"
"I knew a couple. But we kept to ourselves. Each aparmtent had a good door, one that would lock."
"This mother you mentioned, the one who fought with the police, did you know her?"
"No. I'd maybe seen her once or twice. She lived on the other end."
"The other end?"
"Right. There was no plumbing in the middle of the warehouse, so they built the apartments on each end."
"Could you see her apartment from yours?"
"No. It was a big warehouse."
"How big was your apartment?"
"Two rooms, I don't know how big."
"Yeah, they ran some wires in. We could plug in radios and things like that. We had lights. There was running water, but you had to use a community toilet."
"What about heating?"
"Not much. It got cold, but not nearly as cold as sleeping on the street."
"So you were happy with the place?"
"It was okay. I mean, for a hundred bucks a month it wasn't bad."
"You said you knew two other people. What are their names?"
"Herman Harris and Shine somebody."
"where are they now?"
"I haven't seen them."
"Where are you staying?"
Mordecai pulled a business card from his pocket and handed it to Lam. "How long will you be there?" he asked.
"I don't know."
"Can you keep in touch with me?"
"You might need a lawyer. Just call me if you change shelters or find a place of your own."
Lam took the card without a word. We thanked Liza and returned to the office.
* * *
As with any lawsuit, there were a number of ways to proceed with our action against the defendants. There were three of them--RiverOaks, Drake & Sweeney, and TAG, and we did not expect to add more.
The first method was the ambush. The other was the serve and volley.
With the ambush, we would prepare the skeletal framework of our allegations, run to the courthouse, file the suit, leak it to the press, and hope we could prove what we thought we knew. The advantage was surprise, and embarrassment for the defendants, and, hopefully, public opinion. The downside was the legal equivalent of jumping off a cliff with the strong, but unconfirmed, belief that there was a net down there somewhere.
The serve and volley would begin with a letter to the defendants, in which we made the same allegations, but rather than sue we would invite them to discuss the matter. The letters would go back and forth with each side generally able to predict what the other might do. If liability could be proved, then a quiet settlement would probably occur. Litigation could be avoided.
The ambush appealed to Mordecai and myself for two reasons. The firm had shown no interest in leaving me alone; the two searches were clear proof that Arthur on the top floor and Rafter and his band of hard-asses in litigation were coming after me. My arrest would make a nice news story, one they would undoubtedly leak to humiliate me and build pressure. We had to be ready with our own assault.
The second reason went to the heart of our case. Hector and the other witnesses could not be compelled to testify until we filed suit and forced them to give their depositions. During the discovery period that followed the initial filing, we would have the opportunity to ask all sorts of questions of the defendants, and they would be required to answer under oath. We would also be allowed to depose anybody we wanted. If we found Hector Palma, we could grill him under oath. If we tracked down the other evictees, we could force them to tell what happened.
We had to find out what everyone knew, and there was no way to do this without using court-sanctioned discovery.
In theory, our case was really quite simple: The warehouse squatters had been paying rent, in cash with no records, to Tillman Gantry or someone working on his behalf. Gantry had an opportunity to sell the property to RiverOaks, but it had to be done quickly. Gantry lied to RiverOaks and its lawyers about the squatters. Drake & Sweeney, exercising diligence, had sent Hector Palma to inspect the property prior to closing. Hector was mugged on the first visit, took a guard with him on the second, and upon inspecting the premises learned that the residents were, in fact, not squatters, but tenants. He reported this in a memo to Braden Chance, who made the ill-fated decision to disregard it and proceed with the closing. The tenants were summarily evicted as squatters, without due process.
A formal eviction would have taken at least thirty more days, time none of the participants wanted to waste. Thirty days and the worst of winter would be gone; the threat of snowstorms or sub-zero nights would be diminished, along with the need to sleep in a car with the heater running.
They were just street people, with no records, no rent receipts, and no trail to be followed.
It was not a complicated case, in theory. But the hurdles were enormous. Locking in testimony of homeless people could be treacherous, especially if Mr. Gantry decided to assert himself. He ruled the streets, an arena I was not eager to fight in. Mordecai had a vast network built on favors and whispers, but he was no match for Gantry's artillery. We spent an hour discussing various ways to avoid naming TAG, Inc., as a defendant. For obvious reasons, the lawsuit would be far messier and more dangerous with Gantry as a party. We could sue without him, and leave it to his co-defendants--RiverOaks and Drake & Sweeney--to haul him in as a third party.