Chapter 22 - The Deposition Table
The conference room on the twenty-fourth floor of the downtown Cleveland high-rise smelled of expensive leather, lemon-scented furniture polish, and corporate power. Rain lashed against the floor-to-ceiling panoramic windows, obscuring the view of Lake Erie in a wash of gray water.
Bradley Vance sat at the head of the polished granite conference table, flanked by two junior associates with open laptops. Allison sat to his right, wearing an impeccably tailored charcoal pantsuit, pearl earrings, and an expression of cool, detached indifference. She didn't look at Marcus once when we walked through the double mahogany doors; she treated our presence with the dismissive annoyance one might reserve for an unpaid delivery driver.
Thomas Ellery sat to my right, placing a modest yellow legal pad and two pens on the table. Marcus sat directly beside me, wearing a simple dark blue suit I had bought him for his college graduation fifteen years ago—the only suit he had kept that hadn't been seized by the bankruptcy trustee. It was slightly loose around his shoulders now that he had leaned out from physical labor, but he wore it with an upright, quiet dignity that no expensive Italian label could have provided.
A court reporter sat at the end of the table, her fingers resting poised over the keys of the stenograph machine.
"We are on the record," Bradley Vance announced smoothly, glancing at the digital clock on the wall. "In re: Linda Marie Miller Estate. This is the deposition of Walter Miller, Executor. Mr. Miller, you have been sworn."
Vance didn't waste time with pleasantries. He immediately launched into an aggressive, confrontational line of questioning, his voice clipped and theatrical.
"Mr. Miller, isn't it true that during the summer of last year, your late wife Linda expressed severe anxiety regarding your son Marcus’s corporate debts?"
"She was worried about his soul, Mr. Vance," I answered calmly. "Not his balance sheets."
"Let's stick to the numbers, Mr. Miller," Vance snapped, leaning forward. "Did your wife not receive multiple written and verbal requests from Mrs. Allison Miller regarding the preservation of marital equity in connection with the Chicago acquisition?"
"Allison never spoke to my wife about equity," I stated firmly. "Allison only spoke to Linda when she wanted someone to pay for her catering bills or watch her dog while she went to the Hamptons."
Bradley Vance smiled thinly, turning a page on his legal pad. "Hostile characterizations won't help you, Mr. Miller. What we have here is an intentional pattern of hiding family wealth. We have financial records showing that over the course of seven years, Marcus Miller transferred over seven hundred thousand dollars into this household through various accounts—money that came directly from marital business revenues!"
Allison nodded slightly, her face an unyielding mask of righteousness.
"That's a lie," Marcus spoke up, his voice cutting through the room with the force of a thunderclap.
Bradley Vance sneered, turning his gaze toward Marcus. "Mr. Miller, you are not the deponent. You will remain silent until you are questioned, or I will have you cited for contempt."
"Cite me," Marcus said, not flinching an inch. He reached down into his worn leather satchel, pulled out an accordion file thick with bank statements, tax returns, and corporate ledgers, and slammed it onto the granite table so hard the water glasses rattled.
"What is that?" Vance asked, his eyes narrowing.
"That," Marcus said, leaning across the table and locking his eyes directly onto Allison, "is the complete forensic audit of the Miller Group LLC, covering every fiscal quarter from 2017 to the date of dissolution. It was completed by the federal bankruptcy trustee two weeks ago."
Allison shifted uncomfortably in her chair, her sunglasses hanging from her fingers, a faint crack appearing in her composed facade.
"You want to talk about marital equity, Allison?" Marcus continued, his voice calm, measured, and devastatingly clear. "Let's talk about the forty-two thousand dollars you withdrew from my corporate payroll account in June of 2021 to purchase a membership at the Lake Forest Country Club under your maiden name. Let's talk about the thirty thousand dollars you wired to your personal brokerage account three days before we flew to Italy—funds that were supposed to cover our warehouse employees' health insurance premiums."
"Objection!" Vance barked, slamming his palm on the table. "This is irrelevant, harassing, and outside the scope of this deposition!"
"It is entirely within the scope of your complaint, counselor," Thomas Ellery countered smoothly, adjusting his glasses. "Paragraph twelve of your petition claims that Allison Miller was an innocent financial contributor to the marital estate. These certified bank records prove that she was an active, knowing beneficiary of corporate embezzlement who systematically looted the debtor company for personal gain."
Allison’s face drained of color. She grabbed Vance’s arm, whispering frantically into his ear. Vance’s confident smile had vanished, replaced by a dark, furious scowl as he flipped through the top pages of Marcus’s ledger.
"Where did you get these records?" Vance demanded, glaring at Marcus.
"I work twelve hours a day dispatching freight, Mr. Vance," Marcus replied, his voice steady as stone. "And every night for the past three weeks, I sat at my mother’s kitchen table with an accountant provided by my bankruptcy trustee. I went through seven years of receipts. Every single dime my mother ever gave me was documented. Every single dollar Allison took out of my company was tracked to her personal checking account."
Marcus leaned back in his chair, folding his hands over the file. "If you file this lawsuit against St. Jude’s Children's Hospital, Mr. Vance, we will countersue Allison for fraudulent conveyance and corporate conversion. We will turn every single page of this audit over to the United States Trustee and the Internal Revenue Service."
Marcus turned his head, looking directly into the wide, terrified eyes of his former wife. "My mother died while I was sipping wine in Italy, Allison. I spent four months drowning in the shame of what I did. I am completely broke. I have nothing left to lose. But you... you have plenty left to lose. So go ahead. Call your witnesses. Let's take this to a public jury."
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The conference room became so quiet that the rapid clicking of the stenographer’s machine seemed deafening. Bradley Vance looked down at the documents, then at Allison’s trembling hands. He closed his folder with a heavy, defeated snap.
"We are off the record," Vance said quietly.
