Just concerned for your safety. That's my job. Safety then. I appreciate your concern.
Am I free to go? He gestured toward the door. She gathered her belongings, but this time she kept her phone out. Recorder still running, walked through the metal detector.
It didn't beep. In the hallway, she stopped the recording, saved it with the file name Mundy threat 10-17, uploaded it to cloud storage immediately. Then she climbed the stairs to the third floor.
Courtroom 4B looked exactly like every other courtroom she'd seen. Wood paneling on the walls, rows of benches for the gallery, tables for counsel, one on each side. The judge's bench elevated above it all. American flag and North Carolina flag flanking it.
The room was empty except for a bailiff arranging files at the clerk's table. Camille took a seat in the gallery and opened her binder. The advancement motion was 12 pages. Four primary arguments.
First, irreparable harm to Mrs. Hughes if the eviction proceeded before the hearing. Second, inadequate notice violated due process. Third, scheduling the hearing after the eviction rendered the court's review meaningless. Fourth, justice delayed is justice denied.
She'd cited eight cases, three North Carolina Court of Appeals decisions, two state Supreme Court cases, three federal cases on procedural due process, all directly on point. At 8:55, the door opened. A man walked in wearing a charcoal suit that probably cost more than Camille's monthly rent. Late 40s, graying at the temples in a way that made him look distinguished rather than old.
Leather briefcase with brass fittings. Gold watch that caught the light. Elliot Chandler. She'd researched him thoroughly.
Duke Law School, class of 2002, graduated top 15%. Spent 5 years at a white-shoe firm in Charlotte doing corporate defense, made partner, then surprised everyone by taking a 60% pay cut to join the Durham City Attorney's Office as a senior attorney. That was 11 years ago. In those 11 years, he'd never lost a case under 42 U.S.C.
Section 1983. Never lost a civil rights complaint, never had a judgment entered against the city in any case he'd personally handled. He was very, very good at what he did. And what he did was protect the city from people like Camille.
Elliot sat at the respondents table without acknowledging her, pulled files from his briefcase, arranged them in neat stacks, clicked his pen once, twice, then settled back in his chair to wait. At 9:00 a.m. Exactly, the bailiff stood. All rise. The honorable judge Maxwell Hargrove presiding.
A door behind the bench opened. Judge Hargrove entered in his black robe, reading glasses hanging from a chain around his neck. 64 years old, 23 years on the bench. Duke Law class of 1987.
Same graduating class as Camille's father, Fourth Circuit Judge Roland Booker. They'd been friends in law school, study partners, stayed in touch over the years, had dinner together when Judge Booker visited Duke for alumni events. But Camille didn't mention that, wouldn't mention it, not unless it became necessary. Judge Hargrove sat, gestured for everyone else to do the same.
First matter, Hughes v. Greenfield Properties. Emergency TRO. Camille stood. Camille Booker for petitioner, your honor.
Elliot rose smoothly. Elliot Chandler for respondent, your honor. Judge Hargrove looked at Camille over his reading glasses. Really looked at her.
His eyes took in her age, her appearance, the Duke clinical program folder she carried. Something flickered across his expression. Not quite dismissal, but close. Miss Booker, this is an emergency temporary restraining order.
Tell me what makes it an emergency. Your honor, my client is a 62-year-old disabled woman facing unlawful eviction this Friday without proper notice under North Carolina General Statute 42-26. The landlord provided only 72 hours written notice instead of the required 30 days. Mrs. Hughes uses a wheelchair and supplemental oxygen therapy for chronic respiratory issues.
She has no family in the area and limited financial resources. If she's evicted from her current accessible housing, she'll have nowhere to go and no means to secure alternative housing on such short notice. This constitutes immediate and irreparable harm. Judge Hargrove's expression didn't change.
How long have you been practicing law, Miss Booker? The question landed like a brick. She kept her voice steady. I'm a third-year law student, your honor, certified to practice under North Carolina General Statute 84-4.1 through Duke Law School's clinical program.
I'm supervised by Professor Jamal Washington, who has 18 years of So, you're not a lawyer. I'm certified to appear in court and represent clients under supervision, your honor. The statute. I know what the statute says, Miss Booker.
What I'm asking is how much practical courtroom experience you have. How many cases have you argued? How many TROs have you successfully obtained? She felt the trap closing.
Answer honestly, and he'd use her inexperience against her. Hedge and he'd call her evasive. This is my 14th appearance in court, your honor. I've argued six motions, three of which were granted.
I have successfully obtained two preliminary injunctions in family court matters. But your honor, my experience level doesn't change the fact that the law requires that counsel understand not just the statutes but how to apply them and that understanding comes from experience. Judge Hargrove picked up her motion, flipped through it. You've written quite an impressive brief here.
Lots of citations, very thorough, but it reads like a law school exam, Miss Booker. Academic, theoretical. Behind her, Camille heard someone enter the courtroom. Soft footsteps, the creek of a bench as they sat down.
She didn't turn to look. Your honor, with respect, North Carolina General Statute 42-26 is quite clear. It mandates 30 days written notice for Judge Hargrove held up a hand. I can read, Miss Booker.
What I want to know is whether you understand the standard for emergency relief. Can you tell me what rule 65 requires? Yes, your honor. Rule 65 requires the moving party to show one immediate and irreparable harm, two, likelihood of success on the merits, three, that the balance of hardships favors the moving party, and four, that the public interest wouldn't be disserved by granting the injunction.
And you believe you've met that standard? Yes, your honor. Mrs. Hughes will lose her housing. That's irreparable harm.
The landlord violated the notice statute that establishes likelihood of success. Mrs. Hughes is disabled and has nowhere else to go while the landlord is a corporate entity that can easily wait 30 days. That's the balance of hardships. And the public interest favors ensuring that landlords comply with tenant protection statutes.
Elliot Chandler stood. Your honor, if I may, Judge Hargrove nodded. Go ahead, Mr. Chandler. Your honor, respondent moves to dismiss.
Petitioner failed to serve opposing counsel with the required notice under Rule 65(b). Emergency TROs require notice to the adverse party except in very limited circumstances. Miss Booker provided no such notice. Camille was already opening her binder.
Tab three. Certificate of service printed on Duke Law letterhead. Notarized seal at the bottom. Your honor, I have the certificate of service right here.
The motion and all supporting documents were served on Mr. Chandler's office via email and certified mail on October 11th, 4 days ago. Elliot's tone stayed patient, almost kind, like he was explaining something to a child. Your honor, email service is insufficient for emergency motions. This is basic civil procedure.