was Ben’s investigator. He’d bumped heads with Ben years ago under adverse circumstances (Ben represented his wife in their divorce) but nonetheless became a fiercely loyal member of Ben’s team. He was a huge bear of a man; his shoulders were broad enough to fit snugly between two goalposts. “What’s the bottom line?”
Ben flipped to the last page of the Complaint. “Paragraph Fourteen. For the aforementioned injuries, plaintiffs seek actual damages for injuries incurred, damages for emotional distress, pain and suffering, and punitive damages for the willful and wanton acts of the Defendant in an amount not less than one million dollars.”
Loving pursed his lips and whistled. “That’s some Complaint, Skipper. You really think you could get a million bucks?”
“He’d better get more,” Jones commented. “It’ll probably cost that much just to try this sucker.”
“The amount requested in the Complaint doesn’t really mean anything,” Ben explained. “I didn’t want to stir up trouble by tossing out too huge a number. Between now and trial, we’ll figure out what to ask the jury for. Frankly, a million dollars wouldn’t even cover our clients" medical bills.”
“When are you planning to file this, Ben?” Christina asked.
“Right now. Assuming you three don’t have any changes or suggestions?”
“And when will the big boys down at Raven, Tucker & Tubb get it?”
“Just as soon as it’s filed. I’m going to walk it over to the Bank of Oklahoma Tower and hand-deliver it myself.”
“Uh, Skipper,” Loving interjected, “have you considered, maybe, usin" a courier service?”
“Why?”
Loving tossed his copy down on a desk. “I don’t think you wanna be around when the powers-that-be read this.”
“You’re exaggerating.”
“I don’t think so. A Complaint like this could do some real damage to an outfit like Blaylock. "Specially once the press gets wind of it.”
“Which they will,” Jones interjected. “Blaylock will have to take this case very seriously.”
Ben didn’t respond. Deep down, he knew they were right. Blaylock would perceive this as a threat to their corporate integrity, not to mention their bottom line. Raven, Tucker & Tubb would perceive this as an opportunity to rack up some major billable hours. This suit would be big news throughout the legal community—in fact, probably throughout the state.
“All the more reason for us to get to work,” Ben said. “I expect each of you to give this case your full attention. Whatever else you’ve got going, put it on the back burner. We have to move fast or we’re going to get trampled.” He handed each staff member a legal pad that outlined their assignments. “Christina, I know you’re getting close to finals. Do you have time to do some intensive legal research?”
“Of course. I make it a practice never to study for final exams until the night before.”
Ben rolled his eyes. “I think we can fairly anticipate Raven will try to bury us in a sea of motions. They’ll take advantage of the fact that they have a hundred lawyers and we have one.”
“One and a half,” Christina corrected.
“As you say. You think you can anticipate what they’ll file?”
She shrugged. “Sure. Discovery motions. Motion to dismiss for failure to state a claim.”
“Exactly right,” Ben said. “And the last is the one that scares me. Find some similar cases. Some legal precedent in our favor.”
“I know I can find similar cases,” Christina answered. “In fact, I’ve already found some. The Woburn, Massachusetts, case that was in that book, A Civil Action. The Tom’s River case. The outbreaks in Montana and east New Jersey. The problem is—they all feature plaintiffs who get creamed.”
“Find one that’s different. It’s critical that we be able to show the judge we have some potential for success at trial.” He turned his attention to Loving. “We’re going to need some witnesses to prop up
Cheyenne McCray
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