CHAPTER THIRTY
Mary settled in at the deposition next to her client, Alex Chen, Director of Marketing at London Technologies. He was about her age and easily the most attractive deponent she’d ever defended, not that that mattered, since she didn’t want to reverse-sexually harass. Alex was tall, well-built, and officially edgy in a leather motorcycle jacket, which he had on with skinny jeans and a crisp white tailored shirt, no tie. His hair was longish, with hip sideburns, and he had a dazzling smile, which was probably a job requirement in a marketing director.
The court reporter sat at his stenography machine, and opposing counsel, Marcus Benedict, sat across the table, an older preppy from Barret & Tottenham, one of the white-shoe firms that used to be completely populated by old preppies that had outlived their usefulness, like a legal appendix. Benedict still dressed in a three-piece suit and had horn-rimmed glasses, though not the ironic kind. His laptop sat open in front of him, but he had written his questions on a legal pad and was taking Chen through them in a methodical, chronological fashion, which worked for Mary. Her laptop was open and she was typing away, multitasking. Lou had told her that the female reporter was named Amanda Sussman, and Mary couldn’t wait to start digging and see if Sussman was connected to Machiavelli.
“Mr. Chen, please state your name and place of birth for the record.”
“Alexander Thomas Chen. New York, New York.”
“And what is your date of birth?”
“July 3, 1991.”
“And where did you attend college?”
“Penn State.”
“Did you graduate?”
“Yes.”
“When did you graduate?”
Mary tuned out through the endless preliminaries, went online, and typed “Amanda Sussman.” A clean, modern website popped onto the page, with a posed picture that Mary recognized as the female reporter dogging her steps. In the web photo, Sussman looked more corporate than scruffy and was smiling in a stock-photo sort of way. She was probably in her early twenties, had short brown hair, and wore a light blue turtleneck that matched her eyes as well as the font color of her website.
“Mr. Chen, where were you first employed upon graduating from Penn State?”
“I worked at a startup called LockIn.”
“And what was your position there?”
“I was an assistant in the marketing department.”
Mary read the bio on Sussman’s “About Amanda” page.
Amanda Sussman is a freelance writer who specializes in blogging, web content, and print content. She has a legal background and worked as a paralegal for two years. She also has a background in graphic design and has crafted webpages for companies in a variety of industries and she also blogs for B2C and B2B businesses. She can write anything, from features to brochureware, and she can help your company create promotional materials to help expand your customer base.
“Mr. Chen, now that we’ve been through your academic and employment history, we come to London Technologies. How long have you been marketing director at London Technologies?”
“Four years.”
“And who held that position before you?”
“No one.”
Benedict blinked behind his bifocals. “So is it fair to say you were the first marketing director?”
“Yes.”
“And why is that?”
“I don’t understand the question,” Alex answered, and Mary glanced over, proud of him. She had prepared him for his deposition over sandwiches in her office, and he was sophisticated enough to know the basic drill, which was answer only the question asked, don’t volunteer, and if you don’t understand the question, say so.
“Mr. Chen, why was there no marketing director before you?”
“If you know,” Mary interjected, which was her favorite interruption. It always served as a reminder to the witness to stick to the facts, and not be helpful or even show off, because the person on the other side of the table was an enemy.
“I don’t know,” Chen answered.
Mary returned her attention to the website, since she knew the deposition wouldn’t be important until later. The website read: Amanda’s articles and pieces concern a variety of topics, including fast-breaking news stories, business and CEO profiles, and developments in law, real estate, personal finance, and retail in the Philadelphia area. Her specialty is helping people and businesses become major influencers in the Delaware Valley and beyond. Click here if you want to see her portfolio of articles.
Benedict consulted his notes. “What are your duties as marketing director for London Technologies?”
“To help market the company.”
“Mr. Chen, can you elaborate?”
“Briefly, my job was to oversee our direct mail, and advertising to sell our data integration software to furniture retailers.”
“Was one of your duties also to attend trade shows?”
“Yes.”
“Where are they located?”
“They move around the country.”
“How often are they held?”
“Three times a year.”
Mary half-listened, knowing they were getting closer to why Chen had been called as a witness. In the meantime, she clicked to see the type of article Sussman wrote and skimmed the titles: “5 Common Pleas Court Judges You Need to Avoid, If Possible”; “The Biggest Mob Case You’re Not Watching, or Joey Merlino Strikes Again”; “10 Restaurants Near Family Court That Are Cheaper Than Filing Costs”; and “Around the Roundhouse—An Insider’s Guide to Philly’s Police HQ.” Mary made a mental note of the last one, but was wondering if there was a list of clients anywhere on the website.
“Now Mr. Chen, was one of your duties also to attend trade association conferences?”
“Yes.”
“How many trade associations does London Technologies belong to?”
“Just one.”
“And that is?”
“Home Furnishings Group, or HFG.”
“How often do you attend those conferences?”
“Twice a year.”
Mary noticed a link on the website for “Amanda’s Clients,” clicked, and skimmed the list which varied from restaurants, boutiques and bars, with corporate at the bottom. EDWARD BLACKEMORE & ASSOCIATES, THE GUPTA GROUP, NATHAN & RADDATZ, LLC. Mary recognized them as small law firms, but there was no mention of Machiavelli. Then she realized if Machiavelli had hired Sussman, he would’ve made it confidential, so it probably wouldn’t be on the website. She felt momentarily stumped, then got an idea.
“Mr. Chen, where are the conferences located?”
“The October conference moves around the country, but the April conference is in High Point, North Carolina.”
Benedict turned a page of his notes. “Let’s discuss the first HFG conference you attended. Do you recall when that was?”
“Yes.”
Listening, Mary felt proud of Chen again. Anybody else would’ve supplied the more complete answer, but he was proving to be a professionally badass witness. Meanwhile, she navigated to “Contact Amanda” on Sussman’s website and clicked. An email form popped onto the screen, and Mary typed: Dear Amanda, It was great seeing you at the Roundhouse today! Rosato & DiNunzio could use an enterprising freelancer like you! Why don’t you ditch Nick Machiavelli and come work for the good guys? Either way, we’ve got your number. Regards, Mary DiNunzio.
Mary added a CC to Machiavelli, then hit Send.
“Mr. Chen, when was the first HFG conference you attended?”
“In October, 2015.”
“And where did it take place?”
“At Lake Harmony in the Poconos, at Harmony Spa & Conference Center.”
“Did you attend alone?”
“No.”
“With whom did you attend?”
“I went with Jim and Sanjay.”
“And by Jim and Sanjay, do you mean the owners of London Technologies?”
“Yes.”
“How long did the conference last?”
“Two days.”
“Mr. Chen, did there come a time after a breakout session, when you spoke with Jeremy Dietl, president of Home Hacks, one of the defendants in this matter?”
“Yes.”
“And how did that come about?”