Chapter 336: The Bottom Drawer of the Filing Cabinet

At ten a.m. on February 1, the Intermediate Court clerk's number came up on Shen Zhixia's phone with three items: the pretrial meeting was set for 9:30 a.m. on February 18, Fourth Courtroom; both sides would exchange evidence, and the appraisal and preservation applications would be heard together; and finally: "Sort through those papers you've got. Anything not submitted at the pretrial meeting, don't pull it out later."

"Noted."

"On the eighteenth, both people from the defendant's side will be there." The clerk hung up.

She wrote the date and time on the page inside the case file cover, then set the pen down and held it there for a moment. The eighteenth was still more than half a month away, with a New Year in between.

At nine a.m. on February 2, another call.

"Lawyer Shen, it's Qi." He coughed first. "The decision to support the lawsuit has been made. The Supporting Prosecutor's Opinion will be drafted after the holiday, and I'll deliver it to the Intermediate Court on the first workday. I'll be at the pretrial meeting."

"What will the opinion say?"

"I only write what I've verified." He paused. "And one more thing I said before, saying it again: prosecutorial support doesn't mean we fight for you. On the eighteenth, it's you doing the talking in that courtroom. I sit off to the side."

"I remember that."

"I need to go take a look myself before I put anything on paper. No need for you to come along." He hung up.

At three p.m., the litigation service platform pushed through a service notification.

Two documents. The first was titled Statement of Defense, five pages. The second was two pages, headed Objection to Plaintiff's Standing.

She read the five pages first. Dryly written: no admission of discharge, no admission of causation, no admission that a child's test report proved anything; request to dismiss the plaintiff's claims in their entirety. One argument per page, no blank space between sentences, even punctuation kept to a minimum.

Then she turned to the second document.

Point one: the plaintiff's articles of association list environmental education and community service as their purpose and main business scope, so the plaintiff is not an organization specifically engaged in environmental public-interest activities.

Point two: in 2023, the Jiangzhou Civil Affairs Bureau took action against the plaintiff, meaning the plaintiff has a record of violations within five years before filing suit.

Beneath that, one line: request that the court rule to dismiss the lawsuit.

She set the papers back on the desk, pressing her palm down on the corner of the page. These were the phrases she herself had written countless times in complaints. Turned back on her, the paper felt cold.

Lu Jibai finished reading both documents before he spoke. "He came upstairs on January thirtieth and asked two questions. What were they?"

"Registration year. Whether the articles of association still existed."

"He also said the third claim was more substantive than the first two."

"That was for our ears." He squared the two pages of the Objection together and tapped them against the desk. "This is what he actually wanted. Take down standing, and the case stops right here—the ditch doesn't get in, the land doesn't get in, no appraisal needed."

"What about everything already submitted?"

"It all comes back with it."

[Thud. He doesn't ask what's in the ditch. He asks who has standing to ask about the ditch.]

She wrote "dismiss the lawsuit" in her notebook, stopped at the last character, and traced over it again.

"Stop tracing." Lu Jibai pulled a folder from the metal cabinet, opened it, and drew out a printed page. "This provision was in the file the day we submitted our materials. We just never thought we'd need to read it aloud."

He slid the page toward her, held his finger on the third paragraph, and read: "Where a social organization's articles of association define its purpose and main business scope as safeguarding the public interest and it engages in environmental protection public-interest activities, it shall be deemed an organization specifically engaged in environmental protection public-interest activities."

"The part about no record of violations is further down."

"Where no administrative or criminal penalties have been imposed for violations of laws or regulations in the course of business activities within five years before filing suit, it shall be deemed to have no record of violations."

She stared at the words "administrative penalty" for a moment. "His paper says 'took action against.'"

"The judicial interpretation says 'penalty.'" Lu Jibai put the page back. "That interpretation wasn't attached the day we submitted. Tomorrow we go to Qinghe, pull the articles and this, and check the originals."

At ten a.m. on February 3, third floor of Qinghe.

The room was colder than downstairs. Yesterday's newspaper was spread across the long table they'd pushed together, with the thermos set on top to hold it down. Cai Qingru hung her down jacket over the back of a chair and asked, "What two points did he write?"

"The first says the Center isn't specifically environmental—that it does environmental education and community services. The second says the Civil Affairs Bureau took action against the Center in 2023, so there's a violation record within five years."

Cai Qingru said nothing. She pulled her chair back, squatted down, and opened the metal cabinet against the wall. Four shelves. The bottom drawer had to be held in place as it came out, or it would slide back on its own.

"Annual report," she said. "One year, it was filed late."

She pulled a kraft paper envelope from the drawer, the flap curled. From inside she worked out two sheets, stood up, pressed them flat on the long table, and smoothed them with her palm.

The first page was headed with the Jiangzhou Civil Affairs Bureau letterhead. The substance: your Center's 2022 annual work report was not filed within the prescribed period; you are ordered to file within ten days from receipt of this notice; failure to file after the deadline will result in handling according to law. A red seal at the bottom, dated March 2023.

The second page was a receipt, confirming the materials were received, with the handler's signature and another stamp.

"Was there any fine?" Shen Zhixia asked.

"Not a cent."

"Any page with the word 'warning' on it?"

"No. Just this page, plus that receipt." Cai Qingru pulled her hand back. "The books were a mess that year. The 2022 ledger—Yu Min missed the filing. The notice came, and on the eighth day we submitted the supplementary materials. The person who accepted them signed the receipt. After that the annual reports went in year by year—2024, 2025, both on time."

Shen Zhixia held the two pages up to the window side by side. Nothing written on the backs. The red seal pressed square and true against the paper.

Lu Jibai took the copy-certification stamp from his briefcase, then a pen. "Write one line on the copy."

"What should it say?"

"'Verified against the original,' sign it, write the date." He handed the pen to Cai Qingru.

She wrote as instructed, signed, dated: February 3. Then she looked up. "If this page goes in, will the Center still be able to take on government work after this?"

"This page only states that the 2023 incident was not a penalty," Shen Zhixia said. "Nothing more."

"They won't read what I write on this page." Cai Qingru's voice was low. "What they'll see is 'this Center has been disciplined before.'"

"Then I'll put that sentence front and center." Shen Zhixia said. "No dressing it up."

The original articles of association came out of the top shelf of the cabinet—blue cover, frayed corners. Cai Qingru flipped to the first page and spread it flat on the table. "First article of purpose. Read it to him."

Lu Jibai moved the page toward himself and read, character by character: "To carry out environmental protection public-interest activities, promote public participation, and safeguard environmental public interests." When he finished, he let the pen rest on the paper. "That's the first article he didn't cite. The 'business scope' article mentions environmental education and community services. That's the one he cherry-picked."

"He didn't pick wrong," Cai Qingru said. "Those two are what we do most."

"The judicial interpretation says the organization's purpose and main business scope as defined in its articles must be safeguarding the public interest, and it must engage in environmental protection public-interest activities." He laid the three items side by side. "Does environmental education count as an environmental protection public-interest activity? The first article of the charter already answers that."

Shen Zhixia flipped open her notebook. "The second point needs an answer too. He's leveraging that 2023 document."

"That document is called a Notice of Order to Correct Within a Deadline." Lu Jibai pushed the notice to the upper portion of the table. "An order to correct is not a category of penalty. Fines, warnings, confiscation, orders to suspend operations—those are penalties. An order to correct doesn't cost a single cent, nor does it record any disciplinary action against the Center. It tells you to fix something, and once it's fixed, it's done."

"Second layer," he added. "The judicial interpretation says 'for violations in the course of business activities.' An annual report is a filing with the Civil Affairs Bureau—it's not sampling ditch water. These two things don't belong in the same drawer."

[Thud. The page marked "order to correct" can't extract a single yuan.]

Cai Qingru stood by the table, both hands braced on its edge, not sitting down.

"If we lose, will this page get dragged out to say the Center is dirty?"

"It will," Shen Zhixia said. "They're already saying it today. That's why we can't leave this page vague."

"Fine." Cai Qingru stacked the two pages and pressed her palm down once. "Make four copies. One to the court, one kept with you. The originals go back in the cabinet."

Back at Zhengping's second floor by 3:30. Li Huilan sat in the chair by the window. When she saw Shen Zhixia come in, she moved her teacup aside, clearing half the desk.

Three pages. Page one addressed the charter—copying the first article of purpose and the first article of business scope line by line, not a word cut. Page two addressed the 2023 document—stating its exact name, who issued it, why, the deadline, when correction was completed, whether any fine was imposed. Page three stated the request: that the court not sustain the objection and continue hearing the case; if necessary, hear both sides at the pretrial meeting.

Her first draft had included the line "the defendant's agent misconstrued the articles of association." Lu Jibai crossed it out.

"Don't judge him," he said. "Just report what we have."

"This sentence too?"

"It goes. The dispute is over what the documents say and who's reading them right or wrong. The panel will decide that for themselves."

She deleted it, struck through the word "misconstrued," light strokes. Then deleted an "obviously" and a "as everyone knows."

Li Huilan spoke from the window seat: "Who are these three pages written for?"

"The panel."

"Then put your request in the first line. Don't make them flip to page three to find out what you want."

She moved the request to the top, added page numbers to the corners of all three pages, and counted them twice.

Four p.m. Litigation service platform.

She named the file according to firm protocol: plaintiff's written opinion, with date; three attachments, each name shorter than the last. When she uploaded, the page spun twice and showed "Submitted, pending receipt." She stared at the screen, fingers still.

Lu Jibai stood beside her, laying the two copied notice pages side by side to verify again—the position of the certification stamp, the handwriting of the date.

A few minutes past four, the page refreshed: "Received."

A receipt generated, with a case number. She screenshotted it, saved it in the "Qingshi Village" folder, and saved another copy to the desktop; then printed the screenshot. The paper came out of the printer still warm. She fanned it twice with her hand and slipped it into the case file.

"Saved," she said.

"Send Qinghe a copy," Lu Jibai said. "Let them know it went in."

[Thud. Before the holiday, these pages entered the file. The rest belongs to time.]

She set down her pen and added a line inside the case file cover: February 3, 4 p.m., written opinion filed with the Intermediate Court. When she finished, she looked out the window. The stalls in the alley had already closed. The couplet seller was stuffing the last few scrolls into a cardboard box.

The courts would be closed the next several days. On another page of her notebook she wrote the three things to make clear at the pretrial meeting: appraisal, preservation, objection. When she finished, she drew a line under "preservation" and stopped.

"Let's go," Lu Jibai said, handing her coat over. "Downstairs for noodles."

Six p.m., February 4, in front of Zhengping Noodle House.

The roll-up door was down, only a foot of gap at the bottom. A sheet of red paper was pasted to the doorframe, brush-inked by hand: Open again on the eighth of the new year. Big characters, each stroke pressing down hard enough to wrinkle the paper.

He Xiufen stood on a small stool, smoothing one corner of the red paper.

"Tomorrow the door gets sealed. Tonight you can still eat." She said. "Come down and carry it. Don't sit upstairs waiting."

Zhi'an crouched by the door wiping tables, wringing the rag out dry, face flushed. "Sis, should I wipe this board by the door too?"

"Go ahead."

Shen Zhixia looked up at the red paper. Open on the eighth—no fire in the kitchen until then. Only the New Year's Eve dinner.

"Where are we eating on New Year's Eve?" she asked.

He Xiufen stepped down from the stool, pushed it against the wall, clapped the dust from her hands, looked down at both their faces, and wiped one hand on her apron.

"Four tables. Same as always."