Seated in the open air outside The Honor Bar on Coast Village Road in Montecito, Jeff Dalkin reads the Complaint filed in Washington D.C. Superior Court that names him as a Defendant. It alleges that he is a co-conspirator in a plot to harass, invade the privacy and generally destroy the career of a freelance investigative reporter.
"Who wrote this thing," Dalkin mutters, "Alex Jones?"
The summons alleges that Dalkin worked for an entity called Ding-a-Ling Widgets and orders him to file a Response within 21 days.
Dalkin taps a number on his phone to connect with Dick Mutton, the special projects big-wig at Ding-a-Ling Widgets.
"That person is no longer here," says Ding-a-Ling's switchboard operator.
"No? Where is he?"
"We don't have any information on that."
"Okay, what about your in-house counsel, Andy Lotwin?" says Dalkin. "Is he still around?"
"I'll put you through."
"Lotwin," says a voice.
"Jeff Dalkin. Remember me?"
Lotwin does not reply.
"You're right, better you don't remember nothing. Especially me. So what the hell happened to Mutton?"
"He was fired over a year ago."
"It's not anything I'm allowed to talk about," says Lotwin.
"Well, are you allowed to talk about this goddam lawsuit against your widget company—and me?"
"No. We just received the Complaint ourselves. We're studying it."
"You'll take care of my side, of course," says Dalkin. "Right?"
"Does that mean wrong?"
"You're named as a defendant," says Lotwin. "That means you have to find your own counsel to represent you."
"But your widget company is paying for whatever counsel I find, right?"
"I don't fucking believe this," Dalkin mutters. "You're saying I gotta hire a lawyer and cover the cost myself?"
"We can recommend counsel..."
"Yeah, right—somebody who will take my money and look after your interests. Eat my boxer-briefs."
Dalkin disconnects Lotwin and calls the Clerk of the Court, whose phone number is posted on the summons.
"I gotta respond to a Complaint," says Dalkin. "How do I do that?"
"You need a lawyer," says the Clerk.
"I can't afford a lawyer. Lying-labanzas. I'm gonna do it myself. What exactly am I supposed to do?"
"I can't instruct you on that."
"Excuse me, but aren't you the authority compelling me to do something?" says Dalkin. "You could at least tell me how I'm supposed to do it."
"No. You need a lawyer for that."
Although Dalkin had vowed never, ever to return to Washington D.C., that's exactly what is now expected of him—but at least his old-employer is paying.
The FBI wanted him to stay at the Holiday Inn, Chevy Chase, at a government-approved rate—slightly higher than Motel 6—but Dalkin insisted on the Georgetown Inn because it has a decent bar downstairs.
Dalkin's first stop: Bacon, Hump, a behemoth law firm on K Street, with which he had scheduled an appointment.
Bradley Fatwood, senior partner, greets Dalkin and sits him in his corner office.
"So, let's hear it," says Fatwood.
"First off," says Dalkin. "This plaintiff lives in Maryland. Her lawyer is in West Virginia. Ding-a-Ling Widgets, they're in Virginia. And I live in California. Why is this lawsuit filed in Washington D.C.?"
Fatwood nods. "Black juries."
"That's cynical," says Dalkin.
"That's life." Fatwood shrugs. "Did you bring the Complaint?"
Dalkin plucks a wad of paper from his canvas brief bag, hands it to Fatwood, who places it neatly on one corner of his desk before hunching over a yellow legal pad. "Now how about the facts."
"We're going back almost ten years," says Dalkin. "Ding-a-Ling was the first client I had after leaving the F-F... fuck-wanks of ineptitude – B-I."
Fatwood studies his new client with a puzzled expression.
"Oh, yeah, right. I’ve got Tourette's syndrome," says Dalkin. "I curse uncontrollably. It’s called Copo-Copo-Coporalia—whew! Certain words set me off. That's partly why I left the F-F... fornicating fatheads! – B-I. My superiors always thought I was cussing them out. Most of the time”—Dalkin winks—“I really was. It became obvious I wasn't going anywhere. Unless you count North Dakota as somewhere, which I don’t."
"Tell me what you remember about this case," says Fatwood.
"Ding-a-Ling was concerned about being unfairly targeted by a freelance investigative reporter. She'd written a magazine article that exposed all kinds of dirty laundry from the owner of Ding-a-Ling’s closet. And then it looked like she was going to write a book. So they called me and asked what I could do about it. I said, write your own damn book and get it published before hers. It would muddy the market and you'd have your own story out there."
"They liked the idea. I hired a researcher and a writer and they did a book about Ding-a-Ling Widgets. But the muckraker was still out there muckraking. Ding-a-Ling wanted to know why she was targeting them. You know, like, what was her motivation? She was freelance, not a staff reporter for a newspaper or magazine. And Ding-a-Ling thought maybe she was getting money from a competing widget company to embarrass them. They said, can you find out why she's so obsessed with us? I said, sure. “So I plant myself in a place where I know this muckraker hangs out and she comes on to me, tells me her Ding-a-Ling article should be turned into movie because she thinks I'm Bruce—willie wankstain—Willis." Dalkin smirks. "I sort of look like him."
"Sort of?" Fatwood nods. "You look exactly like Bruce Willis."
Dalkin shakes his head. “No, he looks exactly like me, lucky bastard.” He winks. "She yaks her head off about who, what, where, when, why and how. My biggest problem is getting her to shut the fuck up."
Fatwood notes this. "Go on."
"The muckraker sends me all her material, tells me the names of her sources, including a few informants at Ding-a-Ling. Then I suggest to her that she ought to investigate another subject for a possible screenplay. I divert her onto someone other than Ding-a-Ling. I pay her to do this. Good money. Ding-a-Ling’s money, of course.”
“She spends the next two years digging dirt on The National Enquirer. And when she's all done, I tell her we can't possibly make a movie that offends the celebrity tabloids but nice try. The muckraker tries to market it herself, gets nowhere. By then I've stopped taking her calls."
"Do you still work for Ding-a-Ling?" asks Fatwood.
"Did Ding-a-Ling ever indemnify you against legal action?"
Dalkin shrugs. "Everything I did, I did as their paid agent, with their knowledge and approval. Shouldn’t they pay for my defense?”
"I'll make some calls. But I'm going to need a retainer from you to get started."
"Five thousand dollars."
"Fuck me." Dalkin scratches his head. "I'll give you twenty-five hundred."
Bradley Fatwood takes it.