“You have a witness?”
“Yes, sir. Walter Gibson, the licensed surveyor who conducted the boundary assessment filed by Witmore Development.”
Ashton stood immediately.
“Objection. Mr. Gibson is our witness.”
Caldwell looked at Andre for a moment. He seemed ready to deny it. One more way to tilt the floor. But 30 people were watching. A clerk was recording. So he said, “The respondent has a right to cross-examine.”
“Overruled.”
Walter Gibson took the stand. He was a heavy-set man in his 50s with a receding hairline and sweat already forming at his temples. He sat down, adjusted the microphone, and looked at Andre.
He had not expected to be questioned by a 10-year-old.
Andre began gently, carefully, the way Ruth had taught him.
“Mr. Gibson, how long have you been a licensed surveyor?”
“26 years.”
“And you conducted the boundary survey submitted in this case?”
“I did.”
“Could you walk me through your process? Specifically, where did you begin your measurement?”
Gibson relaxed. This was his territory, familiar ground.
“I started from the GPS coordinates of the county reference marker on the northwest corner of the Witmore parcel. Standard procedure.”
“Standard procedure,” Andre repeated. He nodded. Let Gibson feel comfortable. Let him settle in.
Then Andre reached into the briefcase and pulled out two transparent sheets — hand-drawn overlays on clear plastic, traced from the documents he’d studied. One showed the original county plat survey from 22 years ago. The other showed Gibson’s survey.
He held them up, one on top of the other, and walked toward the witness stand. His head barely reached the railing.
“Mr. Gibson, in the original plat recorded with this county 22 years ago, the reference monument on the northwest corner is located at this position,” he pointed, “but in your survey, the starting GPS coordinate is here,” he pointed again, “that’s approximately 14 feet to the east. Can you explain why your starting point is not the same as the original?”
Gibson blinked.
“It was updated.”
“Updated by whom? The coordinates I used were the most current available.”