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Authors: Randy Singer

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BOOK: By Reason of Insanity
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"I'm sure," Quinn said. "But here's the bottom line: I'm prepared to waive all that. I'm prepared to sign a deal today, right now, that says I won't contest custody
if
Annie loses. But there is one condition."

He had their attention. Even Richardson didn't interrupt.

"Sierra can't handle a temporary custody battle right now. She needs stability. She needs a familiar environment. She's too emotionally distraught to be forced into a reconciliation arrangement with a father she doesn't even know." Quinn leaned forward and felt his throat tightening. There was so much at stake. "If Annie and I lose the case, even if the jury enters a compromise verdict of guilty but mentally ill, you get sole custody of Sierra. No court battles. No contest of any sort. Just a reasonable visitation schedule for me. In exchange for that promise, you agree not to file for custody or visitation rights until Annie's court case is resolved. And if Annie wins,
she
gets permanent custody, and
you
get reasonable visitation.

"In the meantime, I'll put Sierra in a stable situation where she can get counseling and recover from some of the psychological blows she's been suffering. If you care about your daughter, you'll give her a chance to get back on her feet."

For a few long seconds, nobody spoke. Quinn's heart rate spiked but he tried to seem calm, as if he held all the cards.

"Give me a minute to talk to my client," Richardson said.

Ninety minutes later, Quinn signed the documents and promised to get Annie's signature later that night. He thanked the two men and hustled out of the building before they could change their minds.

The weight of the case now threatened to crush him. Quinn was a trial lawyer, accustomed to pressure and high-risk litigation decisions. But nothing in his past had prepared him for a case this personal, with stakes this high. If he won, he could save the lives of Annie
and
Sierra, the two women he cared about most.

And if he lost, he might destroy them both.

Only time would tell whether this was a brilliant litigation strategy or legal suicide.

71

The next day, Quinn received Dr. Mancini's written psychiatric evaluation of Catherine O'Rourke. They would, of course, only use it if Catherine could be convinced to plead insanity. The first part of the report was loaded with qualifiers--"This report assumes, without independent investigation, the integrity and credibility of the forensic evidence linking Ms. O'Rourke to the various crimes attributed to the Avenger of Blood." But the main part of the report was vintage Mancini, providing insights that had never occurred to Quinn--or anyone else for that matter.

Later that day, Melanie set up a conference call for Quinn, Rosemarie, and Marc Boland so that the expert could explain her findings.

"There are three factors that allow me to support a diagnosis of dissociative identity disorder," she said confidently. "First is the type of rape that Catherine experienced at William and Mary. It was a former boyfriend, compounding the emotional devastation of rape with the betrayal of trust. Also, it occurred while she was drugged, meaning that she endured this humiliation primarily at a subconscious level, wounding her psyche in a way that her conscious mind never totally comprehended.

"Second, as I detail in the report, the identity for the Avenger of Blood seems to come from an undergrad comparative religions course Catherine was taking at the time of the rape. Alter personalities often exhibit traits consistent with the environment that existed when the personality was first created, even if the alter personality does not manifest itself until years later. It's almost like a snapshot frozen in time. This is one of the ways we distinguish between patients who fake an alter personality and patients who are genuinely psychotic. Catherine, of course, would have no way of knowing this."

Rosemarie paused for a moment. "Are you guys still there?" she asked.

"Just taking notes, professor," Quinn said.

"Good stuff," Marc Boland echoed.

"The third thing," said Rosemarie, "is that I think I've discovered the triggering event. I spent a couple of days digesting reams of newspaper articles written by Catherine. She's an excellent reporter. Her writing is clear, fair, objective, sometimes even detached. But the tone of her writing on Annie's case was very different.

"From the beginning, she seemed more of a cheerleader than a reporter. Plus, it seemed to me that she almost obsessed over it. Her writing was much more emotional than the other articles. Quinn, I think this alter personality saw what Annie did and absorbed your strong defense of your sister, even before that case went to trial. In some ways, I think it gave this personality permission to seek its own revenge, mirroring what Annie did. Perhaps coincidentally, perhaps not, the blood avengers that Catherine learned about in college were the three female furies of Greek mythology, acting as bloodthirsty prosecutors for crimes against innocent victims. In a way, Catherine felt a sense of bonding with Annie--they're both female furies for the twenty-first century."

It made sense, Quinn thought, scribbling furiously. He was already thinking about ways to dramatically illustrate this at trial. The jury would eat it up--Greek mythology, handwriting on the wall, a tortured subconscious. Freud couldn't have written a better script.

"Once I started putting this together, I was curious about how Quinn came to be involved in the case," Rosemarie said. "Marc explained that it was Catherine's idea to hire him and that Catherine had been pretty adamant about it. This fits my theory, Quinn. Subconsciously, Catherine's alter ego wanted Annie's defender to take her case too."

Rosemarie paused again. "There's more, but most of it is in my report. Do you two gentlemen have any questions?"

Quinn loved the report and remained quiet. Not surprisingly, Marc Boland jumped in.

"I do have one question," he said. "How do we convince Catherine that pleading insanity is her best hope?"

"I think that job is best left to her white knight," said Rosemarie.

Quinn didn't argue. In fact, he rather liked the analogy.

72

Airplane flights had long ago lost any novelty for Quinn, but as he and Sierra left Vegas for Virginia Beach, his niece had her face plastered against the window. She had a perfect view of the Vegas skyline, the El Dorado range, and Lake Mead as the plane climbed to cruising altitude. The flight was not crowded, so Quinn took an aisle seat, leaving the seat between him and Sierra empty.

When the Fasten Seatbelt light went off, Sierra broke out her iPod and moved into the center seat, closer to Quinn. Before long, the gangly teenager had curled into an awkward sleeping position, propping her pillow against Quinn's shoulder. Though it hurt the injured shoulder, he didn't move until Sierra fell asleep. Then he leaned over and kissed her on the forehead. It was amazing how much his niece had already changed him.

Quinn's thoughts turned to Annie and her stoic good-bye with Sierra last night. Though being separated from Sierra tore at Annie's heart, she had put on a brave face and tried valiantly not to show her emotions.

Overall, Annie seemed to be weathering jail pretty well. She was a survivor. Plus, Quinn had called in some favors to get Annie her own cell in a minimum-security wing of the Vegas jail, with work responsibilities as a jail trustee. Doing time was never easy, but Annie's situation was certainly better than Catherine's.

Quinn and Sierra landed at the Norfolk airport, dropped their stuff at the Hilton Garden Inn in the Virginia Beach Town Center, and headed straight for the jail. On the way, they stopped at a Borders so Sierra would have something to read while Quinn met with Catherine.

Quinn's goal for today's meeting was not an easy one--convince Catherine to plead insanity. Marc Boland had broached the subject initially, and Catherine had resisted. If Quinn couldn't convince her, the attorneys had agreed they would petition the court to allow them to plead insanity over the objections of the client. It would be much easier if Catherine just agreed.

Quinn left Sierra reading in the visitors' area near the front desk of the jail and proceeded through the metal detector and two thick, remote-controlled doors that separated the jail proper from the lobby area. Going through the doors always gave Quinn a sinking feeling; the claustrophobic block walls of the narrow hallways had a way of sucking hope out of a person. Jail was no place for someone like Catherine O'Rourke. She needed help, not punishment.

Quinn took his seat in the phone-booth-size cubicle that served as the attorney interview room. Within minutes, Catherine arrived on the other side of the thick glass.

It had been only two weeks since Quinn had seen her, but the change was unmistakable. She still had the haunting beauty that had seared itself into Quinn's memory--the dark eyes and sculpted face--and her spiked hair actually looked stylish, the sort of look a movie star might sport a few weeks after shaving her head for an important role. But Catherine's eyes seemed less full of life than Quinn remembered, and her entire face had the contour of unshakable sadness--a downward sloping of the mouth and eyes that made no secret of her depression. Quinn expected her to look hardened. Instead, he saw melancholy.

She thanked him for coming, and he asked her a few questions about life behind bars. She answered politely and then had a question of her own. "How's Sierra?"

The question reminded Quinn that his family drama had played itself out on the world television stage and that inmates watch a lot of television.

"Doing better," Quinn said. "I actually brought her with me."

"Here?" Catherine asked. "To the jail?"

"Yeah. She's out in the visitors' area."

A small spark flickered briefly in Catherine's eyes. "You think I could talk with her tonight during visiting hours? I know a little about what she's going through. Maybe I could encourage her."

Quinn and Sierra had no specific plans that night. "I don't see why not," Quinn said, though the request took him a little off guard. Before receiving Rosemarie's report, Quinn had worked hard to separate these two cases--Annie's and Catherine's--filing them away in different emotional compartments. For some reason, it seemed a little dangerous to blur the lines.

"Thanks," said Catherine. "Visiting hours start at seven."

Quinn nodded. "For now, I want to talk about a possible insanity plea," he said. "I know that Marc has already broached this with you."

Catherine nodded and Quinn noticed her stiffen a little, reminding him that his client had a mind of her own.

He leaned forward. "I know you don't like the implications of an insanity plea, but my job is not to make you like me." Quinn paused, realizing that he cared very much whether this particular client liked him. He might even care a little too much. "My job is to keep you alive and get you out of here. My job is to keep a needle out of your arm."

"Do you believe I did these things?" Catherine asked. Her voice was flat but still conveyed resolve. "Do you think I kidnapped and killed those babies? Do you think I electrocuted Paul Donaldson--fried him to death and dumped his body into the Dismal Swamp Canal? Do you think that's me?"

"It doesn't matter what I think--"

"It matters to
me
," Catherine said.

Quinn swallowed and stayed fixed on her gaze. "I don't know whether you did or not." It was gut-level honest, and he knew Catherine could sense his sincerity. "I only know that right now, we don't stand a chance of convincing a jury that you're flat-out innocent."

"But I
am
innocent," Catherine said. "I need you to believe that. I know it doesn't seem that way. Sometimes I doubt it myself. But, Quinn, I could never hurt those kids. Not this Catherine. And not some other side of me either."

Quinn nodded. "I believe that," he said softly. In truth, he didn't know what to believe. Emotionally, Catherine made a compelling case. If he could just let her talk to the jury like this, the way she was talking to him right now, as if she wanted to reach out and grab his shoulders and make him look straight into her soul, a jury might believe her. But court didn't work that way. The path to justice was littered with the land mines of cross-examination. Emotion would yield to evidence and logic. And logic would always dictate the same unwanted result.

"That doesn't change my advice," said Quinn. "As a friend, I believe you. But as a lawyer, I've got to give you my best
professional
advice. That advice is to plead not guilty by reason of insanity."

"I didn't do it," Catherine insisted. "How can I say that I did?"

An idea hit Quinn. "State your name for the record," he said.

"What?"

"I'm going to show you. We can't possibly win this case on a straight-up not guilty plea if we don't put you on the stand. So you're on the stand, and I'm Boyd Gates. State your name for the record."

A look of determination hardened Catherine's face. "Catherine O'Rourke," she said, squaring her jaw.

73

"Do you consider yourself a medium, Ms. O'Rourke?"

"No. Not really."

"And yet you just happened to know information about the crimes committed by the Avenger of Blood--information that the police had not released to anyone?"

BOOK: By Reason of Insanity
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