Parnell Hall - The Anonymous Client

“Therefore I will ask you this: on Wednesday, October ninth, did you have occasion to go to 249 East 3rd Street?”

“Yes, I did.”

“Why did you go there?”

“Now,” Steve said, “you are inquiring into matters as to which I cannot help you. I am afraid that question calls for information of a privileged nature between client and attorney. Therefore I must decline to answer.”

“What the client told you is privileged information. What you did is not.”

Steve smiled. “Aren’t you splitting hairs here, Dirkson? You’re asking me, in effect, if a client told me to go to Bradshaw’s apartment. If that were the case, it would be a privileged communication, and you can’t inquire into it.”

“Are you stating that such is the case?”

“Certainly not. I am stating a hypothetical point of law.”

“We are not here to discuss hypothetical points of law.”

“I agree. Why don’t you move on to something else?”

Dirkson frowned. “It is not your place to tell me what questions I should ask.”

“Quite right. You can ask any questions you want. I’m only telling you which ones I choose to answer.”

That sally brought grins to the faces of some of the grand jurors.

Dirkson bit his lip. The cross-examination was not going as planned. Winslow wasn’t supposed to be scoring any points. Dirkson needed to get him on the run.

“All right,” Dirkson said. “We’ll play in your ballpark. Let’s talk about what you did. The fact is, you went to that apartment.”

“That’s right.”

“What did you do when you got there?”

This was the part Steve wanted to skip over. He certainly didn’t want to have to admit he’d opened the foyer door with a credit card. In the hope of getting around it, he threw Dirkson a crumb.

“I knocked on the door. When I got no answer, I tried the knob.”

Dirkson pounced on it. “You tried the knob?” Dirkson said. His manner was the same as if Winslow had just confessed to murder.

“And why did you try the knob? Or was that the result of a confidential communication?”

“No, it wasn’t.”

“Well, what was it then?”

“Just a reflex action.”

Dirkson put his skepticism in his voice. “A reflex action?”

“That’s right. I knocked on the door. I jiggled the knob. The knob turned.”

“Just like that?”

“Just like that.”

Dirkson shook his head. “You knew that door was unlocked, didn’t you?”

“No, I didn’t.”

“You suspected it.”

Steve smiled. “You want to interrogate me on what I suspected?”

“Now you’re splitting hairs,” Dirkson said. “You had reason to believe that door was unlocked, didn’t you?”

“No, I did not.”

“Then why did you try the knob?”

“I told you why. I can’t make any better answer than I already have.”

Dirkson gave the grand jury a look. That look was a work of art. In one glance he managed to convey the idea that his work was being impeded by having to deal with a slippery, lying shyster.

Dirkson turned back to Steve. “The door opened and you entered the apartment?”

“That’s correct.”

“And what did you find?”

“I found the body of David C. Bradshaw lying on the floor. He’d been stabbed in the back with a knife.”

“You recognized him as David C. Bradshaw?”

“That’s right.”

“Then you’d seen him before?”

“That’s correct.”

“Where did you see him?”

“In my office.”

“When?”

“The previous day.”

“What was Bradshaw doing in your office?”

“I can’t tell you that.”

“Why not?”

“It’s privileged information.”

“Regarding what client?”

“I can’t tell you that.”

“I’m not asking you what the client told you. I’m asking you the name of the client.”

“I can’t help you there.”

“What business did you have with David C. Bradshaw?”

“I can’t tell you that either. You know that. Look, Dirkson, I’m here as a witness. If you want to ask me about what I did, fine. If you want to ask me about my business, go roll a hoop. You know the law.”

Dirkson took a breath. “All right. You found the body of Bradshaw?”

“That’s right.”

“What did you do when you found the body?”

“First I made sure he was dead.”

“How?”

“I felt for a pulse.”

“Where?”

“On his wrist.”

“So you touched the body?”

“I touched the wrist, yes.”

“Is that the only place you touched the body?”

“That’s right.”

“You didn’t move the body in any way?”

“No.”

“What about the clothing on the body?”

“What about it?”

“Did you touch the clothing?”

“My hand may have brushed his shirt feeling for the pulse.”

“That’s not what I’m asking. You know what I’m getting at. Did you search the body in any way?”

“No, I did not.”

“Put your hands in any of the pockets?”

“No.”

“None of the pockets?”

“No.”

“Did you take anything out of any of the pockets?”

“No.”

“You certain?”

“Absolutely.”

“I see. Then let me ask you this: did you put anything in any of the pockets?”

“No, I did not.”

“You did not?”

“That is correct.”

“You understand you’re under oath?”

“I object to that question.”

Dirkson looked at him. “What?”

“I object to the question.”

“I just asked you if you knew you were under oath.”

“Exactly,” Steve said. “It’s a thoroughly objectionable question. I’m a lawyer. I know what it means to be under oath. Your asking that is a snide attempt to imply to the grand jury that you don’t believe what I’m saying.”

“No, it isn’t.”

“Then what is it?”

“It’s a question.”

“Sure, it’s a question, but it’s not a question designed to elicit any information. It’s merely an attempt to belittle my testimony.”

“How could that belittle your testimony?”

“I told you. By implying you don’t believe what I’m saying.”

“I don’t believe what you’re saying,” Dirkson blurted.

Steve smiled. “There you are.”

Dirkson suddenly realized he was fighting a losing battle. “All right,” he said. “Let’s get back to what you did. When you entered Bradshaw’s apartment, did you have any money on you?”

“Certainly.”

“You did?”

“Of course I did. I always carry money on me. So many taxi drivers don’t take checks.”

“This is no joking matter.”

“I agree. Then ask me a question that makes sense. Everyone carries money.”

“You know what I’m getting at,” Dirkson said. “When you entered that apartment, did you have a large sum of money on you? To be specific, did you have ten thousand dollars in one thousand dollar bills?”

“No, I did not.”

“You deny that you had ten thousand dollars on you when you entered that apartment?”

“Yes, I do.”

Dirkson crossed to the prosecutor’s table and picked up a piece of paper.

“Mr. Winslow, I hand you a piece of paper and ask you if you have seen it before.”

“Yes I have.”

“What do you recognize it to be?”

“It is the list of serial numbers off of ten one thousand dollar bills.”

“Where did you get that list?”

“You just handed it to me.”

Dirkson frowned. “Don’t swap words with me. You know what I mean. Last night in my office I asked you to produce a list of the serial numbers of ten one thousand dollar bills. Is that the list you gave me at that time?”