The conference room slled like stale coffee and nervous sweat. David Chen, Operations VP for Hessington Oil's Ecuador division, sat across from flanked by two Pearson Darby attorneys. Harvey wasn't here—junior partners handling preliminary depositions while he focused on criminal trial prep.
Court reporter set up in corner, fingers poised over stenotype machine. I had my questions organized chronologically, evidence exhibits tagged and ready.
"Mr. Chen, you were Operations VP for the Ecuador project from March 2011 through the explosion in January 2013, correct?"
"Yes."
"And you were responsible for operational safety, equipnt maintenance, and regulatory compliance?"
"Among other responsibilities, yes."
"Let show you Exhibit 12." I slid the docunt across the table. "This is an internal email you sent to CFO Marcus Webb on November 15th, 2012. Can you read the highlighted section?"
Chen read silently, face tightening. "I wrote this, yes."
"Read it aloud for the record, please."
"'The gas detection system requires imdiate replacent. Current sensors are failing intermittently. Recomnd budgeting $200,000 for new equipnt installation before year-end.'"
"You recomnded imdiate replacent because the safety system was failing, correct?"
"I recomnded replacent as preventive maintenance—"
"Mr. Chen, the email says 'imdiate.' That's your word, not mine. You believed this was urgent, didn't you?"
One of the Pearson Darby attorneys—junior partner I didn't recognize—interjected. "Objection. Leading."
"Your objection is noted for the record. Mr. Chen, please answer the question."
Chen shifted in his seat. "I believed replacent should be prioritized, yes."
"Because failing sensors created safety risk for workers?"
"As I said, preventive maintenance—"
"Mr. Chen, sensors that fail intermittently cannot detect gas leaks reliably, correct?"
"Correct, but—"
"And gas leaks pose significant explosion risk?"
"Yes, but we had secondary protocols—"
"We'll get to those. Now, let show you Exhibit 13." Another docunt across the table. "This is CFO Webb's response to your recomndation. Read the highlighted portion."
Chen's expression went carefully neutral. "'Budget constraints require deferring non-critical equipnt replacent to Q2 2013. Continue monitoring with existing systems.'"
"Your recomnded imdiate replacent was denied for budget reasons?"
"The CFO determined it could be delayed—"
"I didn't ask what the CFO determined. I asked if your recomndation was denied for budget reasons. Yes or no?"
"Yes."
"And the explosion occurred on January 18th, 2013—six weeks after your recomndation was denied?"
"Yes."
"Two months before the 'delayed' replacent would have occurred in Q2?"
"I..." Chen looked at his attorneys. One of them made a note but said nothing. "Yes."
I'd gotten what I needed. Direct testimony that Operations VP flagged urgent safety concern, CFO denied it for cost savings, explosion occurred during the delay. Perfect negligence narrative.
The Pearson Darby attorneys took their turn, tried to rehabilitate Chen's testimony. Emphasized secondary safety protocols, regulatory compliance claims, normal business judgnt. But the core admission stood.
Two days later, Harvey showed up for the CFO deposition. Marcus Webb, the executive who'd made the budget decision that killed six workers.
Harvey positioned himself aggressively—next to his witness rather than across the table, body language protective. Classic defense attorney posture.
"Mr. Webb, you received Operations VP Chen's recomndation to replace the gas detection system in November 2012, correct?"
"I received many recomndations. Dozens every month."
"This one specifically. The $200,000 recomndation for imdiate replacent. You rember it?"
"Vaguely."
"Let refresh your mory." I showed him Exhibit 13—his own email denying the request. "This is your response. Does that refresh your mory?"
Webb's jaw tightened. "Yes, I rember now."
"You denied the replacent request to save money, didn't you?"
"Objection," Harvey said imdiately. "Arguntative, assus facts not in evidence."
"Your objection is noted. Mr. Webb, please answer."
"I deferred the replacent because budget analysis indicated it could wait until Q2 without unacceptable risk."
"Who did that budget analysis?"
"My team."
"Nas?"
"I don't recall specifically—"
"Did that analysis account for the possibility of catastrophic failure during the delay period?"
"We assessed risk levels—"
"Did the analysis account for catastrophic failure? Yes or no?"
Harvey leaned forward. "Objection. Counsel is badgering the witness."
"Overruled. The witness will answer."
Webb looked at Harvey, then back at . "We assessed risk as manageable given secondary protocols."
"That's not what I asked. Did your analysis account for catastrophic failure?"
"Not explicitly, but—"
"So the answer is no. Your team did not analyze the risk of catastrophic failure when you denied the $200,000 safety equipnt replacent."
"We believed monitoring protocols were sufficient—"
"You believed saving $200,000 was worth the risk to workers' lives?"
"Objection!" Harvey stood. "That question is inflammatory and assus facts not established."
"Withdrawn." I pulled out another exhibit. "Let show you this email, Mr. Webb. Sent from you to the Board of Directors on October 2012. Read the highlighted section."
Webb read silently, face going pale.
"Out loud, please."
"'Ecuador project achieved $4.2M under budget in Q3 through aggressive cost managent and deferred non-critical expenditures.'"
"You reported the cost savings to the Board as achievent?"
"Cost managent is part of my responsibility—"
"The 'deferred non-critical expenditures' included the gas detection system Mr. Chen said needed imdiate replacent, didn't it?"
Silence. Webb's attorneys exchanged glances.
"Mr. Webb?"
"Among other items, yes."
"So you categorized safety equipnt that Operations VP deed urgently needed as 'non-critical expenditure.' You prioritized cost savings over worker safety. Is that accurate?"
"That's a simplistic characterization—"
"Is it accurate? Yes or no?"
Harvey stood again. "Objection. Counsel is mischaracterizing complex business decisions—"
"The witness can answer, Mr. Specter. Please sit down."
Webb's voice was barely audible. "I made judgnt call that secondary protocols provided adequate safety while we managed budget constraints."
"And six workers died while you 'managed budget constraints,' didn't they?"
"Objection!" Harvey's voice was sharp. "That question is completely inappropriate."
"Withdrawn. I have no further questions for this witness."
After the deposition ended and Webb left with his attorneys, Harvey lingered. We were alone in the conference room except for the court reporter packing up equipnt.
"You're building your civil case effectively," Harvey said. "That doesn't an Ava ordered murders in Africa."
"I'm not trying to prove she ordered murders. I'm proving her company killed six workers through negligence. You keep confusing the two cases."
"They're connected."
"Only in your mind. Criminal conspiracy and civil negligence are separate legal theories with separate evidence and separate standards." I packed my exhibits. "You're defending the wrong battle, Harvey. Your criminal defense strategy is making the civil case worse."
"How do you figure?"
"You're protecting witnesses from criminal exposure by emphasizing cost managent decisions. That's exactly what proves civil negligence. Every ti you let a witness explain their budget reasoning, you hand ammunition for wrongful death case."
Harvey was quiet for a mont. "So what would you do differently?"
"I'd stop conflating the cases. Defend criminal charges as criminal defense. Let civil attorneys handle civil strategy independently. Right now, you're trying to control both, and it's creating contradictions."
"Jessica and I coordinate—"
"Jessica's drowning in rger politics. She's not coordinating effectively." I headed toward the door, then stopped. "You're brilliant at criminal defense, Harvey. But civil litigation requires different approach. Stop trying to do both."
I left before he could respond. Behind , I heard him gathering his materials, probably already planning how to minimize the damage from Webb's admissions.
The depositions had gone well. Better than expected. I'd gotten direct testimony proving that Hessington Oil executives knew about safety risks, chose cost savings over worker protection, and the explosion occurred during the delay they'd imposed.
That was the civil negligence case in three sentences.
Harvey could defend Ava Hessington against murder charges all he wanted. Caron Dennis could prosecute her for conspiracy. Both cases could proceed independently.
Mine would win regardless of their outcos.
Because the evidence was clear, the negligence was proven, and the families deserved justice that had nothing to do with African murders or criminal conspiracies.
Six workers. Preventable deaths. Corporate negligence.
That was the case.
Everything else was noise.
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