Chapter Sixteen
I landed in New York Sunday afternoon to an email from Leo’s assistant with a secure file attachment for Sterling Solomon, Leo’s new client. He would call to go over what he needed me to do.
My cell phone rang Sunday night with an unknown number that I knew instinctively was Leo. I felt a wave of panic. I didn’t know the first thing about film investments. What if he thought I did? What if he expected me to have a game plan?
He went into full partner mode the second I picked up. It sounded like he was dictating a message on his phone.
“Samantha. Hi. Hope you had a great trip back. Two things. We need to draft a breach-of-contract complaint, even though I hope to God we never have to use it. I’ll send over a couple samples, but it’s important that we position this as a straightforward breach of contract, as in you need to downplay the movie aspect.
We don’t want to point out the risky nature of the investment.
Apparently, he never consulted a film finance lawyer, and that type of schmuck decision-making is exactly the information we don’t want in front of a judge.
Find some recent breach-of-contract case law and then get all the facts you need from him tomorrow.
I’m coming to New York in a few weeks to meet him in person, but I don’t want to lose time—so I need you to sit down with him at his office this week and get the full download so we can have a draft of the complaint ready to put in front of him when I get there. ”
I took furious notes as Leo continued speaking a mile a minute.
“Again. We need a coherent complaint to placate the client, but between us, I do not want this lawsuit getting filed. His only bet at recovering anything is us coming up with a creative strategy to force a settlement. A judge is going to take one look at these emails and texts and laugh us out of court. We cannot litigate this.”
“Understood.”
I created a new client folder as a second email popped up with three sample complaints attached.
I opened the first one, written on behalf of the wife of a famous athlete who was suing the publisher of her memoir for breach of contract.
The second complaint was for the founder of one of the most popular social media platforms. The third was for a legendary morning-show host who was suing the TV network for ageism.
All Leo’s clients.
I felt an unshakable wave of imposter syndrome.
It took all of ten minutes to read through Sterling’s documents.
It seemed the only undisputed fact was that the film fund had approached Sterling to make an investment in a slate of four movies with budgets of $5 million each for a total of $20 million.
He’d wired the money in one lump sum. Other than that, it didn’t look like he received any formal agreement papering the investment or copies of the movie budgets, and it didn’t even look like he’d asked for them.
It was going to be difficult to meet the minimum standard for a bona fide complaint with such sparse supporting facts.
I quickly summarized the emails and texts into a coherent memo, then began carefully reading each sample complaint and researching breach-of-contract cases with similar fact patterns. There weren’t any.
I went to bed late and woke up early. I hadn’t seen Charlie in almost a week.
I was already used to having someone I could say anything to inside our office bubble.
I texted him as I got off the subway to see if he wanted Joe’s and was disappointed when he responded he was out the whole week for depositions somewhere in the Midwest. He promised to send tallies of oversized SUVs and American flags.
The meeting with Sterling was scheduled for one o’clock the next day on Greene Street in SoHo. A black car would pick me up from the office at noon.
I arrived a few minutes early and buzzed the top floor of the loft-style building.
There was no concierge, but an elevator attendant appeared a few seconds later and scanned a key to the penthouse.
The elevator door opened directly onto a massive loft with garage-style windows and a woman sitting behind an Apple monitor.
“Hi, I’m Samantha DeFiore from Abramson otherwise, you get sanctioned, maybe even disbarred.
Unless we uncovered some more helpful facts, we weren’t getting close.
I wished Charlie was back so I could complain about the cards being stacked against me on my first assignment for Leo Hirschman. No one could draft a compelling complaint for this client, let alone someone with zero experience.
I lost track of time as I plodded through page after page of sentences that I knew would be ripped apart by the other side’s lawyers. The office felt cold and empty.
“How is it one a.m.?” I muttered. But I was wired. The city was sleepier than I was.
My office line rang, jolting me back to reality.
“Knew I’d find you there,” Charlie said. I smiled and wondered how he knew that I needed a friendly voice.
“You’re manifesting my reality when you call me this late.”
“I don’t know what that means.”
“It means the universe knows you’re going to call, and it makes sure I’m sitting here waiting for the phone to ring.”
Charlie clicked his tongue. “I don’t think you need me to manifest your workaholic lifestyle. Pretty sure you do that all on your own. Anyway, I’d bet a lot of money that whatever’s keeping you at the office this late is better than what I’ve been doing all day.”
“How many pickup trucks did you see today?”
“Let me just paint the whole picture. I landed in some bumfuck town, then drove three hours to some even more Podunk town, where I spent the day in a warehouse trying to find FOIA documents in a filing cabinet that was built when Teddy Roosevelt was president. Then I carried one box back to my car and drove thirty minutes to make copies. You can guess what happened next. Meanwhile, you’re going to barbecues in Malibu.
I’d ask, ‘Where did I go wrong?’ but I don’t think I can handle the answer right now. ”
I smiled at the image of Charlie stuck somewhere in Middle America. “What’s FOY-UH?”
“Freedom of Information Act. Someone mentioned it once during orientation—it’s like the best and worst tool to request government docs.
Tax filings and all that stuff. They literally respond with everything under the sun, and you have to wade through the mountains of paper they generously send to find the one thing you actually need. ”
“Sounds like an environmental crisis.”
“No shit.”
“Well, thanks for the pick-me-up. I know you don’t believe me, but I needed it.”
“Figured you missed me.”
I nodded silently. “You’d think I’d love having this view to myself, but the truth is, it’s starting to feel a little creepy. Especially late at night.”
Charlie groaned. “Fuck, how is it only Wednesday? My flight back isn’t till tomorrow night. We’re due for a proper catch-up. I want to hear all about LA and this new case and whatever new yoga class you found.”
I hung up and stared at my screen, imagining Charlie in a Midwestern warehouse wading through bureaucratic sludge. FOIA. The acronym felt burned on my brain.
I needed a break from the complaint, so I opened my research document and read through the notes I’d taken on the four movies Sterling invested in.
Curious, I typed “Tokyo Summer movie” into Google and clicked the “News” tab.
A few reviews popped up at the top of the page.
One headline caught my eye: “New Indie Production Shoots NYC’s Chinatown to Pass for Tokyo.
” I read the first line of the article: “While New York State may be more tax-credit friendly than Japan, the producers are being crucified for assuming Americans are that stupid . . .”
I sighed. Sterling couldn’t have gotten involved with a less legitimate group.
And then it hit me.
I swiveled behind me to the bookshelf where I kept three textbooks and all the books on entertainment law I had bought before law school.
I grabbed The Biz by Schuyler Moore and scanned the table of contents for the tax-credits chapter.
It was only a couple of pages long but enough of a refresher to know what I needed to find out.
I grabbed my phone and excitedly texted Charlie. You’re a freaking genius.