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.

But Gantry was a contributing cause in our theory of liability, and to ignore him as a

defendant would be to ask for trouble as the case progressed.

Hector Palma had to be found. and once we found him, we somehow had to convince him

to either produce the hidden memo, or to tell us what was in it. Finding him would be the

easy part; getting him to talk might be impossible. He quite likely wouldn't want to, since

he needed to keep his job. He'd been quick to tell me he had a wife and four kids.

There were other problems with the lawsuit, the first of which was purely procedural. We,

as lawyers, did not have the authority to file suit on behalf of the heirs of Lontae Burton

and her four children. We had to be employed by her family, such as it was. With her

mother and two brothers in prison, and her father's identity yet to be revealed, Mordecai

was of the opinion we should petition the Family Court for the appointment of a trustee to

handle the affairs of Lontae's estate. In doing so, we could bypass her family, at least