The Rainmaker (1997)

1. My father hated lawyers all his life.

2. He wasn't a great guy, my old man.

3. He drank and beat up my mother. He beat me up, too.

4. So you might think I became a lawyer just to piss him off,

5. but you'd be wrong.

6. I'd wanted to be a lawyer

7. ever since I read about the civil rights lawyers in the '50s and '60s

8. and the amazing uses they found for the law.

9. They did what a lot of people thought was the impossible,

10. they gave lawyers a good name.

11. And so I went to law school,

12. and it did piss my father off, but he was pissed off anyway.

13. In my first year, he got drunk one day,

14. fell off a ladder manufactured by the company he worked for,

15. and he didn't know who to sue first.

16. Well, he died a couple of months after that.

17. Now, some of my classmates,

18. they knew they were going straight from school into the top law firms,

19. thanks mostly to their family connections.

20. Now the only connections I had

21. were made in the places where I tended bar for three years

22. so I could pay my tuition.

23. And while I still had plans to shine the blazing light of justice

24. into every dark corner, what I really needed right now

25. was a job, and badly.

26. Because there are too many lawyers in Memphis.

27. This city's infested with them.

28. I don't think so.

29. I can't think of anything more embarrassing...

30. No.

31. than telling people I work for a guy like Bruiser Stone.

32. Maybe.

33. - I mean, he's a lawyer... - No.

34. and they call him Bruiser.

35. That's how desperate I am.

36. Sure.

37. Shut the door.

38. No, not that. Not that, either.

39. Sure.

40. Sure.

41. Let's make it... Let's make it my house.

42. Okay.

43. I really pity the poor FBI technician

44. who's gonna have to extract the data from that conversation.

45. Live sharks in a lawyer's office. It's a joke, get it?

46. So, Prince, is this the law student you were telling me about?

47. Yes, sir.

48. Just finished my third year at Memphis State.

49. Couldn't you use him around here?

50. Look, I'll vouch for him. The boy needs a job.

51. He's tended bar at our clubs.

52. This would be a great place for you to work, Rudy.

53. This would be a great place for you to work.

54. You'd see what real lawyers do.

55. Now, it ain't exactly a salaried position.

56. It isn't?

57. I expect my associates to pay for themselves.

58. Generate their own fees.

59. Talk to me.

60. How exactly does that work?

61. Well, Rudy, you draw $1,000 a month

62. and you get to keep one third of all the fees that you generate.

63. Now, if you can't cover your draw at the end of each month,

64. you owe me the balance. Do you understand?

65. Sounds fair to me, Rudy. And that's a hell of a deal, really.

66. You make a lot of money this way.

67. I'll tell you something, Rudy. That's the only way I operate.

68. - And I'll get you a lot of good cases. - I have cases.

69. I have two cases right now.

70. One is a will that I'm drafting for an old woman.

71. She's loaded, too. She's worth millions.

72. And then I have this other case, it's an insurance case.

73. Great Benefit. You heard of them?

74. You got these clients signed?

75. I'm on my way to see them right now, and they'll listen to me, too.

76. I helped them over at a law workshop.

77. All right, I'm gonna have you talk to an associate of mine, Deck Schifflet.

78. He used to work with these big insurance companies.

79. He handles all the high-powered stuff around here.

80. Hey, Deck? Deck!

81. Damn it. You got the paperwork on this stuff?

82. - In my car. - Good.

83. Hey, good looking.

84. This is Deck Schifflet. This man'll get you plugged in.

85. What I want you to do,

86. I want you to draw up the lawsuit against this Great Benefit

87. and you put my name on it. We gonna file it today.

88. Thank you.

89. - Thanks, Prince. - Rudy, you gonna learn a lot.

90. Rudy, I'm glad you came here.

91. You're making good choices already, son.

92. - All right, well, thank you. I appreciate it. - Okay. Thank you.

93. Close the door on your way out now, okay?

94. Law Offices. May I help you?

95. This is an office. There's people in it.

96. If there's somebody in the office, you can't have it.

97. It's off limits. This is the bathroom.

98. - Just a minute. - Sorry.

99. - So, are you an associate here? - Sort of. Not really.

100. Actually, I'm not a lawyer yet.

101. Bruiser usually asks me to review the insurance cases when they come in.

102. I used to work for Specific Mutual Insurance Company.

103. I got sick of that, I went to law school.

104. - So when did you finish law school? - Five years ago.

105. Still having a little trouble with the bar exam.

106. - I sat for it six times. - Oh, I'm sorry to hear that.

107. - Yeah, when do you take yours? - I take it in, like, three weeks.

108. Oh, yeah.

109. - Is it that hard? - Pretty rough, I'll say.

110. I took it a year ago. I don't think I'm gonna take it again.

111. Anyway, this is Bruiser's law library.

112. If you wanna get anything out of the fridge or use the fridge,

113. you can put your name on stuff.

114. They'll eat it anyway. Put that in for me.

115. - Okay. - It's only rice. What the hell.

116. - Daisy. - Yeah.

117. - I made a mess here. Pick that up, huh? - Sure, Deck.

118. Anyway.

119. Wait. What happens when you have to go to court?

120. I've actually gone a few times myself. I haven't gotten caught.

121. There's so many lawyers here,

122. it's impossible to keep up with us. Let's go.

123. - Bruiser owns all this. - Oh. Nice.

124. You can't call it a firm, exactly. It's every man for himself.

125. You'll learn.

126. - What? Are you moving? - Evicted.

127. Here's the policy.

128. What do you think?

129. Well, this is the scratch-and-sniff armpit of the industry.

130. - What are their grounds for denial? - Everything.

131. They first denied it just on principle,

132. then they said that leukemia was a pre-existing condition,

133. and then they said leukemia wasn't covered in the policy.

134. I got seven letters here.

135. Have all the premiums been paid?

136. According to Mrs. Black, she paid every single one of them.

137. They're bastards.

138. This is a typical debit insurance scam.

139. The blacks call it streetsurance.

140. - So, what do I do? - You sign them up.

141. You sign them all up to J. Lyman Stone.

142. - All right. - Yeah.

143. I'll help you on this one. Yeah.

144. All right. Well, thank you. I appreciate it.

145. There's nothing more thrilling than nailing an insurance company.

146. Hi, Mrs. Black, it's Rudy Baylor. Remember?

147. I'm handling your case against Great Benefit.

148. I met you over at the Memphis State law workshop.

149. Well, come in. Come in.

150. - I'm sorry about them crazy dogs. - Oh, that's okay.

151. I thought you was a Jehovah's Witness.

152. - Where's Buddy? - He's out in the car.

153. - Oh, where's he going? - Buddy isn't going nowhere.

154. He ain't right in the head, war injury. Korea.

155. You know them metal detectors at the airport?

156. He could walk through one buck-naked and the thing would go off.

157. Got a plate in his head.

158. Oh, that's awful.

159. How's Donny Ray?

160. Well, good days and bad.

161. "Plate in head."

162. You wanna meet him?

163. Maybe later.

164. Now,

165. Great Benefit first denied your claim last August,

166. when Donny Ray was diagnosed.

167. Why did y'all wait till now to consult a lawyer?

168. Stupid, I guess.

169. I just kept writing them, and they kept writing me back.

170. This here's the latest one.

171. "Dear Mrs. Black.

172. "On seven prior occasions,

173. "this company has denied your claim in writing.

174. "We now deny it for the eighth and final time.

175. "You must be stupid, stupid, stupid.

176. "Sincerely,

177. "Everett Lufkin, Vice-President of Claims."

178. I don't believe this.

179. You're the lawyer.

180. Mom says nice things about you.

181. She says you're suing those bastards over at Great Benefit.

182. - Gonna make them pay, huh? - That's right. That's right.

183. - Hi, Mama. - Hi, honey.

184. Well, before we can file the claim I need all three of you to sign this.

185. Is Daddy coming in?

186. Well, he said he wasn't.

187. Some days he comes in, and some days he don't.

188. Well, this is a contract.

189. - What's in it? - The usual.

190. It's standard language.

191. It basically says that, y'all hire us to be your attorneys

192. and we take care of the case for you,

193. we handle any expenses that we might have

194. and then we get one-third of any recovery.

195. Well, why does it take two pages to say all that?

196. Hey, don't light that.

197. No wonder I'm dying.

198. And all three of us have to sign it?

199. Yes, ma'am. All three. Just where your name is.

200. Well, he said he wasn't coming in.

201. Then take the pen and go out there and make him sign the damn thing.

202. I guess I could.

203. Now, Buddy, you got to sign this paper,

204. so Donny Ray can get that operation he needs

205. and I don't want no trouble out of you.

206. I'll take that damn bottle and throw it across Union Street.

207. Now sign the damn thing. Come on, hurry up.

208. I know you must think they're crazy.

209. They're nice folks.

210. Hey, man...

211. Hey, your nose is bleeding, man.

212. Mrs. Black! Here, hold your head up.

213. Mrs. Black!

214. - All right, all right. - It's okay. I got it.

215. He's bleeding.

216. Okay, put your head back, put your head back.

217. Come on, come on, put it back.

218. Oh, sweetie. Okay, you'll be all right.

219. Oh, my God. I got it. I got it.

220. - Okay, okay. - Okay, I got it.

221. All right, okay.

222. You're gonna be all right.

223. Where's the paper?

224. Donny Ray, why don't you just rest a minute?

225. You can wait. You can wait. You don't have to do this now.

226. No, no, I wanna do this now.

227. Okay.

228. All right, all right, all right, you can do it. Go ahead.

229. You're doing it.

230. Yes.

231. Miss Birdie? It's Rudy Baylor.

232. What? Who is it?

233. It's Rudy Baylor.

234. We met at the law workshop at Memphis State.

235. - Oh, yes! Come in, come in! - Well, thank you. Thank you.

236. - How you doing today? - Fine. Fine.

237. Miss Birdie, I wanted to talk to you about your will.

238. - I wanna cut my children out of my will. - I know.

239. - Cut, cut, cut. - Cut, cut, cut. I know.

240. I had trouble sleeping last night 'cause I was worried about your estate.

241. Now, if you're not careful, Miss Birdie,

242. the government is just gonna get a big chunk of this.

243. Now, a lot of these taxes can be avoided

244. with little bit of careful estate planning.

245. All that legal gobbledygook.

246. I suppose you want your name in the will somewhere.

247. Of course not.

248. Lawyers are always wanting their names in my wills.

249. No, ma'am, I...

250. Well, there are all kinds of lawyers.

251. But what I do need from you is, for purposes of estate planning,

252. I do need to know where the money is.

253. Is it in bonds or stocks or cash?

254. Now, Rudy, not so fast, not so fast.

255. Okay, ma'am.

256. So we have this money somewhere.

257. Who are we gonna leave it to?

258. Well, I want it all to go to the Reverend Kenneth Chandler.

259. Do you know him?

260. He's on television all the time now, out of Dallas.

261. Got this curly gray hair, premature.

262. And he wouldn't dream of touching it up, you know?

263. I want him to have the money.

264. Forgive me, Miss Birdie, but...

265. What?

266. I just have a real problem drafting a will,

267. or any instrument that's gonna cut out family,

268. and it's gonna replace it and convey all the bulk of this estate

269. to a TV personality.

270. Well, he's a man of God.

271. I realize that. I know.

272. Is there any way we could kind of attack this

273. in more of a... Do you have to give him everything?

274. - And his jet is getting old. - His jet is getting old?

275. Now, Rudy, I want you to just please draw it up the way I asked

276. and bring it back to me so I can review it, all right?

277. Here's the hustlers when they was still young and sweet.

278. Cut, cut, cut.

279. You come back now, huh?

280. Oh, I will, I will. Thank you.

281. No, thank you.

282. - Is that a little apartment back there? - Used to be.

283. - What do you think about my garden? - Oh, that's a fine-looking garden.

284. - You do all the work on this yourself? - Most of it.

285. I pay a young boy to cut the grass for me once a week.

286. $30. Can you believe it? Used to be 5.

287. Well, I don't suppose you'd be interested

288. in renting this place out now, would you?

289. I couldn't afford much, though.

290. I could let you have it quite reasonably

291. if you'd assist me with a few chores around the place.

292. Sure. Sure.

293. Perhaps a little weed-pulling now and then.

294. Weed-pulling? Sure. Weed-pulling's my specialty.

295. I go to hospitals all the time.

296. Bruiser has contacts down at the Main Precinct.

297. Guys he grew up with.

298. They feed him accident reports every morning.

299. - Can I ask you something? - Sure.

300. What does Bruiser expect me to do?

301. You get the case, you find the victims,

302. you sign them up to the law firm of J. Lyman Stone, put the case together.

303. So I should solicit?

304. What did they teach you in law school?

305. They didn't teach me how to chase ambulances.

306. Well, you better learn quick or you're gonna starve.

307. No problem.

308. All you need to do is ask your doctor, and we could admit you right here.

309. Sure.

310. - Nice flowers. - Thanks.

311. - William. - How you doing, Deck? All right.

312. 346.

313. - Dr. Wells. - Good morning. How you doing?

314. - Good morning. How are you? - Good. Good to see you.

315. Don't act like a lawyer.

316. "Do not enter."

317. How are you doing, Mr. McKenzie?

318. How are my tests?

319. Gall bladder. Wrong fish.

320. Mr. Van Landel.

321. Good afternoon, Mr. Van Landel.

322. Can you hear me, Mr. Van Landel?

323. Hi.

324. - Who are you? - I'm Deck Schifflet, paralawyer.

325. You haven't talked to any insurance companies, have you?

326. - No. - Good.

327. Don't talk to them because they're just out to screw you.

328. - Do you have a lawyer? - No.

329. My firm handles more car wrecks than anybody in Memphis.

330. Insurance companies are terrified of us, and we don't charge a dime.

331. Can you wait till my wife gets back?

332. Your wife, Mr. Van Landel?

333. Sorry.

334. I'm very sorry, Mr. Van Landel. I'm very sorry.

335. Where's your wife, Mr. Van Landel?

336. Oh, she'll be back in a little while.

337. Well, I'm gonna have to talk to her down in my office

338. because there's a ton of information that I need.

339. Here, just sign right there.

340. Now, remember, don't talk to anybody except your doctor.

341. There are gonna be people coming at you from every direction

342. offering you settlements.

343. I do not want you under any circumstances

344. to sign anything without me reviewing it first, you understand?

345. My number is on this card. You can call me 24 hours a day.

346. Mr. Rudy Baylor's number is on the back.

347. You can call that number for him anytime. Okay?

348. - Do you have any questions? - No.

349. Good. We're gonna get you a bunch of money.

350. Let's go.

351. I'm real sorry about your leg.

352. I'd like to be alone, please.

353. And that is how it's done. Piece of cake.

354. What if the guy had a lawyer?

355. We came with nothing.

356. If he'd have thrown us out of his room, for whatever reason,

357. what have we lost?

358. A little dignity? Maybe a little self-respect?

359. You see, in law school, Rudy,

360. they don't teach you what you need to know.

361. It's all theories and lofty notions and big, fat ethics books.

362. What's wrong with ethics?

363. Nothing, I guess.

364. I mean, I believe a lawyer should fight for his client,

365. refrain from stealing money, and try not to lie.

366. You know, the basics.

367. - That was blatant ambulance chasing. - Right. And who cares?

368. There's a lot of lawyers out there. It's marketplace, it's a competition.

369. What they don't teach you in law school can get you hurt.

370. How do you know when a lawyer is lying?

371. His lips are moving.

372. What's the difference between a hooker and a lawyer?

373. The hooker will stop screwing you after you're dead.

374. Everybody loves lawyer jokes, especially lawyers.

375. They're even sort of proud of them.

376. Why do you suppose that is?

377. "... and the third parties know the defendant..."

378. "... may also be used by plaintiff to be in a third party..."

379. What the hell are you doing?

380. Nothing. I'm studying.

381. I thought we was gonna study on our own time.

382. I know, Bruiser. But look, man, the bar exam is next week, all right?

383. It is next week. I'm scared, man.

384. Hey, Rudy, look, you wanna study?

385. Why don't you run over to the hospital and study with Deck?

386. I'm not gonna study... I'm not gonna study with Deck.

387. Yeah, I got a police report here.

388. Do we represent her?

389. - Is the victim here? - Well, not yet.

390. Why don't you run down to the hospital and check it out?

391. Maybe you could sign her up?

392. Here you go.

393. Now, honey,

394. where did this all come from?

395. You have to tell me where in the hell all this stuff came from.

396. I know what's going on the second I lay eyes on them.

397. Like I'm 10 years old.

398. My father crying in the bedroom, my mother sitting at the kitchen table

399. with blood all over her face, telling me that Daddy's sorry

400. and he's never going to do it again.

401. Honey, don't... Jeez! Just tell me yes!

402. Why are you doing this to me? It's always the same with you!

403. You make me so crazy!

404. Kelly Riker was admitted to St. Peter's Hospital three days ago,

405. at midnight, I might add, with assorted injuries.

406. The cops found her lying on a sofa in the den,

407. beat to hell, wrapped in a blanket, naked.

408. Cliff Riker, her spouse,

409. was obviously intoxicated, highly agitated

410. and initially wanted to dish out to the cops what he was giving his wife,

411. which was, by the way, a severe beating with an aluminum baseball bat,

412. evidently his weapon of choice.

413. Let's talk about Miss Birdie's millions.

414. - Coleen... - No, I wanna talk about Cliff.

415. I wanna talk about what happened to Cliff.

416. He spent the night in jail. His family bailed him out.

417. He's due in court in a week. Nothing will happen.

418. All right, Colleen Janice Birdsong.

419. She did indeed inherit a couple of million bucks

420. from her late second husband.

421. But lawyers, bad trust department investments

422. and the IRS totally devoured the estate.

423. All except for about $40,000,

424. which Miss Birdie probably tucked in her mattress, for all we know.

425. Sorry.

426. You are my sunshine, my only sunshine

427. You make me happy when skies are gray

428. Do not take my sunshine away

429. Oh, good morning, Rudy. Isn't it a lovely day?

430. Oh, yeah, it's beautiful.

431. Oh, here's my mulch!

432. That's right. There. There. There. Right there. Yes.

433. Stop it, stop it, stop it!

434. All right, just put it right there now. My yard boy will get it.

435. Just right down there.

436. Isn't that a fine bunch of mulch?

437. Excuse me.

438. I'm not one to meddle,

439. but are you all right?

440. Are you in pain?

441. No, but thanks.

442. Okay, well, I'm right up here. I'm just studying for the bar exam.

443. So if you need anything just holler at me.

444. - Okay. - Anything, all right?

445. I'll get it for you.

446. - My name is Rudy Baylor. - Kelly Riker. Nice to meet you.

447. Kelly, it's nice to meet you, too.

448. Why don't you sit down? Go ahead, take a seat.

449. What school did you go to?

450. I went to Austin Peay and then law school at Memphis State.

451. I always wanted to go to college, but it didn't work out.

452. - Did you? - Yeah.

453. I always thought I'd go, but it didn't work out.

454. What kind of lawyer do you wanna be?

455. Well, I enjoy trial work so

456. I'd like to spend my days in a courtroom.

457. - Defending criminals? - Maybe. Maybe.

458. They're entitled to a good defense.

459. They have a right to their day in court.

460. Murderers?

461. Most murderers can't afford a private lawyer.

462. Rapists and child molesters?

463. No.

464. Men who beat their wives?

465. Criminal work is a real rare specialty.

466. I'll probably be doing more civil litigation.

467. - Like lawsuits and stuff. - Right.

468. Yeah.

469. Excuse me.

470. Rudy Baylor.

471. Hey there, it's me.

472. What you doing? How's the fishing going?

473. It's going well.

474. I'm actually talking to the prospect right now.

475. Well, you better sign her up.

476. Rudy. Rudy, can you hear me?

477. - I enjoyed meeting you. - Rudy.

478. Yeah, thanks for the company.

479. - Hey, tomorrow night? - Maybe.

480. Time's up. Pencils down.

481. Please pass your test booklets to your right

482. so that your proctors may gather them up.

483. In my first year of law school, everybody loved everybody else

484. because we were all studying the law, and the law was a noble thing.

485. By my third year, you were lucky if you weren't murdered in your sleep.

486. People stole exams, hid research materials from the library

487. and lied to the professors.

488. Such is the nature of the profession.

489. Right here.

490. Half an hour ago, her husband came in and threw a bowl of soup at her,

491. because she just won't get it through her head

492. - how much he loves her. - This is my room.

493. Pregnant at 18, married, then a miscarriage,

494. probably because he beat her up, and still she can't leave him.

495. You are gonna have to help me.

496. Everything I've ever seen, tells me that this girl is a loser.

497. Scarred and broken, and maybe even dangerous.

498. But I've never really seen anyone like her before

499. and instead of running away all I wanna do is protect her.

500. Visiting hours are over, hon. You kids need to wrap it up.

501. So?

502. He should be shot.

503. Any man who'd beat his wife with an aluminum bat needs to be shot.

504. How did you find out?

505. There are police reports, there are ambulance reports,

506. there are hospital records.

507. How long are you gonna wait, Kelly,

508. until he decides to hit you in the head with that bat of his?

509. 'Cause that could kill you, you know? That'd be it.

510. A couple of good shots to the skull and that would be it.

511. Stop it! Don't tell me how it feels!

512. Look at me, Kelly.

513. Can I ask you something?

514. Do you have a father or a brother?

515. Why?

516. Because if my daughter got beat the way your husband beats you,

517. I swear to God, I'd break his neck.

518. No big brother?

519. No.

520. No one to take care of me, you know?

521. Kelly, I'll try to help you in any way I can

522. but you have to file for divorce.

523. Do it now, while you're in the hospital being treated for the last beating.

524. It'll sail through. What better proof is there than that?

525. I can't file for a divorce.

526. Why not?

527. Because he'll kill me.

528. He tells me so all the time.

529. That's not gonna happen.

530. Could you pass me a pillow, please, and put it under my foot?

531. There's one over there.

532. Here.

533. - That okay? - Yeah.

534. Yeah? All right.

535. Could you pass me my gown, too, please?

536. Yeah.

537. Thanks.

538. - You need some help putting it on? - No! Just turn around.

539. All right.

540. Hey.

541. - Who are you? - I live here. Who the hell are you?

542. Oh, my God.

543. - I'm Delbert's wife. - Delbert? Who the hell is Delbert?

544. What do you... How, how did you get in here?

545. Birdie gave me the key. Yes. Who are you?

546. I am the person who lives here. Do you understand that?

547. You have no right to be in here. This is a private residence.

548. Oh, yeah, right, some place. Get a grip. Birdie wants to see you.

549. "... terms of permanence and restrictions mentioned above herein..."

550. What is this?

551. Well, you must be the lawyer.

552. - I'm Rudy Baylor. - I'm Delbert Birdsong, Birdie's youngest.

553. He yelled at me.

554. He told me to get out of his apartment.

555. - That so? - You're damn right that's so.

556. That goes for the both of you.

557. I don't want neither one of you up there going through my stuff.

558. That's private property.

559. I come home to check on Mama

560. and damn, she's got a stinking lawyer living with her.

561. You been messing with my Mama's will?

562. Well, she's your Mama, why don't you ask her?

563. She won't say a word.

564. Oh, well, then neither can I.

565. That's a lawyer-client privilege.

566. But I'll tell you what.

567. I made a couple of phone calls, verified some accounts.

568. Your mama's second husband left her an enormous fortune.

569. How big?

570. Big. Big.

571. I hope you're not meddling, boy.

572. Mama, wouldn't you just love to come and visit with us

573. down in Florida for a while?

574. You'd love it down there, Mama.

575. Mama, come on back here and get some cake, Mama.

576. I'll get us some milk.

577. We're real close to the fountain of youth,

578. and we ain't but 33 miles away.

579. And we're 180 miles from Disney World.

580. - How you feeling, Donny Ray? - Great.

581. I bet I look fantastic.

582. - You feel up to this? - Yeah, let's go already.

583. All right.

584. A lawyer's not supposed to become personally involved with his client,

585. but there's all kinds of lawyers,

586. and all kinds of clients, too.

587. - You okay, baby? - Yeah.

588. Tigers! Tigers! Tigers!

589. Can I get you guys anything else?

590. You want something?

591. I'll have a shot of Jack Daniel's, please.

592. What's it gonna do, kill me?

593. Miss Birdie, this is my friend Donny Ray.

594. Donny Ray, I'm so glad to have you over.

595. Thanks, Miss Birdie.

596. There you go.

597. You just come right over here and sit down. Have a rest.

598. You got me all blocked off here.

599. Miss Birdie, I gotta take a break. My back's killing me.

600. I almost forgot. This came for you.

601. Oh, my God.

602. Isn't it exciting?

603. I'm so proud of you.

604. - I passed the bar. - All right.

605. Take it, come on. Here's to Rudy.

606. - Congratulations on passing the bar. - Thank you.

607. - What the hell is that? - Iced tea.

608. - Congratulations. - Thanks, Deck.

609. That's some good work, boys.

610. I got a check today from the Van Landel settlement.

611. I'm giving you boys a bonus. 5,500 each.

612. - Well, thank you. - Sign up some more cases, huh?

613. Okay.

614. So, are we gonna be ready for tomorrow morning?

615. 9:00?

616. We're gonna argue Great Benefit's motion to dismiss.

617. Yeah, I think we're ready. We're ready.

618. So, Deck and I have been going over it. I think we're ready.

619. Well, I hope so, 'cause I might have you handle some of that argument, Rudy.

620. It would be awfully embarrassing if we lose this case on a dismissal.

621. Boss?

622. Okay, I gotta go.

623. The food's on me.

624. Enjoy your meat.

625. Thanks a lot, Bruiser. Appreciate it.

626. Something's about to go down. I'm sure of it.

627. He's never split money like that before.

628. What do you think's behind his generosity?

629. Come on, man.

630. Oh, yeah?

631. Here.

632. Yesterday, one of Bruiser's ex-partners testified before a Grand Jury.

633. I think he's cut a deal.

634. It's just a matter of time before he's singing on Bruiser.

635. So what? So what?

636. So, you're gonna have to make a move.

637. Make a move? Deck, I just got here.

638. Yeah? Well, things might get a little hot.

639. Jury tampering, tax evasion, money skimming, you name it.

640. I'm nervous, real nervous.

641. Well, hey, what are you nervous about? They can't arrest us.

642. Listen, supposing they come in with subpoenas and hacksaws?

643. They can do that.

644. They've been known to do that in racketeering cases.

645. They come in, confiscate the files, they haul the computers out.

646. What's that leave us?

647. I'm not worried about being arrested, I'm worried about my job.

648. - All right, so what are you saying here? - Let's bolt.

649. How much money you got?

650. - I got $5,500. - Me, too.

651. We can rent a small office, $500 a month.

652. We operate on a shoestring for the first six months.

653. It'd be beautiful.

654. We split everything, everything, right down the middle. Fifty-fifty.

655. Costs, expenses, profits, everything, right down the middle.

656. What's the matter?

657. You don't wanna be my partner?

658. No, it's not... Deck, it's not that.

659. It's just that you're hitting me with this right now

660. and I mean, you gotta give me a minute, all right?

661. I mean, you can't just spring it on me.

662. We have to act fast.

663. All right. Let's do it.

664. - We'll do it for a while, see how it goes. - Okay.

665. How many files do you have?

666. - I got three. - Get them out of there.

667. Take them home. But don't get caught, okay?

668. - Is somebody watching us? - The Feds.

669. Ate too fast.

670. Sorry.

671. Hey, listen, I went by the office this morning.

672. - The FBI was chaining up the front door. - Yeah.

673. - Is Bruiser coming? - I doubt it.

674. Arrest warrants have been issued for both Bruiser and Prince.

675. Oh, man.

676. But don't... Just relax. You can do this. It's just a motion. Come on.

677. - Me? - Yeah.

678. Oh, come on, I'm gonna be sick.

679. You know this case. You're gonna be fine.

680. - Listen, I don't even have my license. - We don't need a license. Come on.

681. I've memorized the Black files cold.

682. I've read all the books on jurisprudence, the rules of evidence and discovery,

683. but I take one look around the courtroom

684. and I realize I haven't even been born yet.

685. Excuse me, sir, Your Honor.

686. I'm here for the Black v. Great Benefit hearing.

687. And who are you?

688. Rudy Baylor. I work for J. Lyman Stone.

689. Oh, you work for J. Lyman.

690. A staunch supporter of the tobacco lobby.

691. Where is Mr. Stone?

692. Honestly, Your Honor, I don't know.

693. He was supposed to meet me here and I don't know where he is.

694. Well, why doesn't that surprise me?

695. So what do you want, you want a continuance?

696. No, Your Honor, I'm prepared to argue this motion.

697. Are you a lawyer?

698. Well, I just passed the bar and these are my clients.

699. Mr. Stone filed this on my behalf until I passed the bar.

700. Well, you got a hell of a lot of nerve

701. walking into my courtroom without a license!

702. Now, get the hell out of here!

703. Get your license and then you come back!

704. Get a license!

705. Come back when you got a damn license!

706. May it please the court.

707. For the record, my name is Leo F. Drummond,

708. of Tinley Britt, counsel for Great Benefit.

709. And I say if this young man has passed the bar exam,

710. Your Honor, let him argue the case.

711. We welcome him to big time litigation.

712. You have no objection, Mr. Drummond?

713. If it please the court,

714. I would be honored to introduce Mr. Baylor

715. to the practice of law in the great state of Tennessee.

716. Judge, you can give him the oath right now,

717. and I'll be pleased to stand for him.

718. Are you certain you're prepared to proceed, Mr. Baylor?

719. Absolutely.

720. Yes, Your Honor, yes.

721. Very well then. Raise your right hand.

722. Do you solemnly swear, Rudy Baylor, that you will support the Constitution

723. and the laws of the United States and the state of Tennessee faithfully

724. and honorably conduct yourself in the practice of your profession

725. to the best of your skills and abilities so help you God?

726. I do.

727. Okay, fine, fine.

728. That's it. Let's move on.

729. - Congratulations. - Thank you.

730. And welcome to the war.

731. Sworn in by a fool and vouched for by a scoundrel.

732. - Harvey? - I'm a lawyer at last.

733. Come on in.

734. May I, Harv?

735. Sure. Sit down.

736. This lawsuit bothers me, Mr. Baylor.

737. I wouldn't use the word "frivolous,"

738. but I'm not impressed with the merits of it, to be frank.

739. I'm gonna try to sneak some gym time in.

740. In fact, I'm really tired of these type of lawsuits.

741. Don't make no excuses.

742. I'm inclined to grant the motion to dismiss.

743. Now, you can re-file it in federal court, you know?

744. Take it somewhere else. I don't want it clogging up my docket.

745. Now, excuse me while I go to the can.

746. See you, too.

747. Rudy, I'm a very expensive lawyer,

748. from a very expensive firm and I've handled a lot of cases.

749. I can hit pretty close to the center of the dart board,

750. and I told my clients, Great Benefit,

751. that cost alone here was gonna be a big deal.

752. And for you, too. Your side, too.

753. Now, they've authorized me

754. to offer you and your clients

755. $50,000 to settle this thing out.

756. And I may even be able to raise that figure

757. up as high as maybe $75,000.

758. No admission of liability, you understand.

759. Of course, if you say no then it's gonna be World War III.

760. - My turn now. May I, Harv? - Sure.

761. There's not much of a lawsuit here, I'm afraid, son.

762. But maybe I can lean on Leo to make you an offer of a settlement.

763. They'll probably wanna throw some money at you

764. to keep from paying Leo a thousand bucks a minute.

765. He already offered me the cost of the defense.

766. Oh, really? How much?

767. $75,000.

768. Jeez!

769. Well, lookie here, son, you'd be crazy not to take that.

770. You think so?

771. $75,000? Jeez, that's a bunch of money.

772. - Doesn't sound like Leo. - He's a great guy.

773. So?

774. That was not a meeting in chambers, that was an ambush.

775. - What happened? - They tag-teamed me.

776. Yeah.

777. Think they would've done that to Bruiser?

778. - No, Bruiser's too savvy for that. - Yeah.

779. - For what? - They offered me 75,000.

780. Good. Take it.

781. Our third is $25,000. We need the money.

782. Judge Hale's serious about dismissing this case.

783. He's just an old angry man

784. who's been sitting on that bench too long.

785. I say, the best thing we can do is grab what we can

786. to make things easier on his parents.

787. The insurance company made an offer to settle.

788. - What kind of offer? - $75,000.

789. They figure that's what it's gonna cost to pay their lawyers to defend the case.

790. Oh, sons of bitches think they can just buy us off?

791. That's exactly what they think.

792. You better talk to him.

793. Do you wanna settle, Rudy?

794. I mean, some of the money's yours.

795. No way.

796. I wanna expose these people.

797. Mama, could you give me a glass of water, please?

798. Sure, baby.

799. Whatever you get out of this case, will you take care of my family with it?

800. I really love them.

801. I can't help thinking that while we're all out there

802. scrambling around for an edge like we're never gonna die,

803. this boy's looking right at it, and he's doing it almost alone.

804. I can't even begin to imagine the courage it must take.

805. Hello.

806. - Guess who died last night? - Who?

807. Do you ever sleep?

808. Harvey Hale, 62, quite a pedigree.

809. - Judge Hale? - Yep.

810. Croaked with a heart attack. Dropped dead in his swimming pool.

811. You gotta be kidding me.

812. You gotta be kidding me.

813. Guess what newly-made judge

814. was assigned Great Benefit case in his place.

815. How in the hell am I supposed to know that, Deck?

816. Tyrone Kipler, black, Harvard, civil rights lawyer.

817. He can't stand Tinley Britt and he's tough on insurance companies.

818. Sues them all the time. Great luck for us. All right.

819. - All right. All right. - You know what a rainmaker is, kid?

820. The bucks are gonna be falling from the sky!

821. Okay, it's 5:00 right now. What time are you coming down?

822. - I'll be down in a minute. - All right, well, get down here.

823. We gotta talk about fast-tracking, all right?

824. - Coffee's on the way. - Okay.

825. Mr. Drummond, you've objected to the fast-tracking of this case.

826. What's the problem?

827. Well, Your Honor, this issue's already been ruled upon by Judge Hale.

828. The preparations required for fast-tracking the case

829. place undue burden on both parties, I believe.

830. Nonsense. Let me ask you something, Mr. Drummond.

831. As a defense lawyer,

832. have you ever agreed to the fast-tracking of a lawsuit?

833. Well, Your Honor, I believe I have.

834. Fine. Give me the name of the case and the court it was in.

835. Well, Your Honor, I'll have to get back to you on that.

836. Well, call me this afternoon by 3:00.

837. I don't believe I'm gonna be in before 3:00.

838. Oh, well, call me when you get in.

839. I'm very anxious to hear about this case you agreed to fast-track.

840. Yes, sir.

841. This boy is about to die, gentlemen.

842. You do agree they would need to record his testimony.

843. Yes, indeed.

844. Of course, Your Honor.

845. Just, my trial calendar's pushing me around pretty good.

846. How about next Thursday afternoon?

847. Great for me, Your Honor.

848. I'm sorry, Your Honor.

849. That's a week from today.

850. I believe I'm out of town. Yes, I am out of town Thursday.

851. The deposition is set for next Thursday afternoon at 2:00 p.m.

852. Sorry if it inconveniences the defense,

853. but God knows there's enough of you guys to handle it.

854. Now, what's next?

855. Well, Your Honor, the motion to dismiss is still pending.

856. Oh, yes. That motion is denied.

857. Well, I guess that's it.

858. Gentlemen, let's go.

859. Congratulations on your appointment, Your Honor.

860. Thank you, sir.

861. And Mr. Drummond,

862. don't forget to call me with the name of that case you agreed to fast-track.

863. I'll look around.

864. You in over your head, son?

865. Absolutely.

866. Now Deck wants to do an ad on the local rap station,

867. and as much as I'd love to hear it, we can't afford it.

868. Furnishings, bar dues, $750 for a fax machine,

869. $400 for lease on a computer,

870. a down payment on a new second-hand car

871. and we're broke again.

872. Deck says he's thrilled with the way things are going.

873. - Rudy, hi! - Hey, Dot.

874. Come in. How are you?

875. I'm doing good. How you doing?

876. Listen, I'm going up to Cleveland Wednesday night.

877. It's the headquarters of Great Benefit.

878. I'm gonna take depositions from all the executives up there, so...

879. And don't worry about expenses, either.

880. We're gonna take care of it.

881. - Thank you, Rudy. - It's no problem.

882. It's awkward.

883. My associate, Deck Schifflet.

884. - How do you do? - Hi.

885. Hey, Rudy, Tyrone's here.

886. Okay.

887. Judge is here.

888. Oh, here, wait, Dot, give me that.

889. - Hello. - Hello.

890. - Come right in. - Thank you.

891. This is Mrs. Black. His Honor, Tyrone Kipler.

892. It's a privilege to meet you.

893. Well, the privilege is mine.

894. Oh, come on in. There's not a lot of room here. Tight.

895. Let's take a look outside. Is that all right with you, son?

896. Sure. Okay.

897. I'll show you the way.

898. I'm looking at a team of lawyers who are pulling down $1,000 an hour

899. and I hate them.

900. From their lofty perch,

901. pissing down on the whole justice system with disdain.

902. I used to hate them because I wasn't good enough for them.

903. Now I hate them for who they represent and what they represent.

904. - Your Honor, how are you? - Fine, sir.

905. Hope the dogs didn't startle you.

906. - We're doing this thing outside? - It's a little cramped inside.

907. Just have a seat here, all right?

908. - How you doing? - Good.

909. Thank you.

910. Hey, Donny Ray.

911. Hey.

912. You've already met Judge Kipler.

913. Howdy.

914. This is Leo F. Drummond and associates.

915. This here's Tammy, she's the court reporter.

916. Swear him in.

917. Do you swear the testimony you are about to give

918. will be the truth, the whole truth

919. and nothing but the truth, so help you God?

920. Yes, I do.

921. - I told him not to... - I know, I know, I know.

922. Come here. Come here. Come here. Don't worry about it.

923. Don't worry about it. It's just a deposition.

924. Donny Ray, I'm Leo Drummond. I represent Great Benefit

925. and I'm very sorry to be here under these circumstances.

926. We wouldn't be here if your clients had done what they should've done.

927. I beg your pardon. I didn't hear that.

928. Hey, kid, you want a stick of gum?

929. - Sure. - Here.

930. - Did you break your arm? - Yeah.

931. - You had an accident? - Why?

932. Well, I'm a lawyer, and give this to your mom. You're his mom?

933. Maybe I can get you some money for the accident.

934. Okay. I'll go help that gentleman first.

935. Oh, no. I got it. It's fine.

936. - Can I help you, sir? - No, I'm just looking.

937. There's a cinema down the street. Buy a ticket. Center section, back row.

938. I'll be there in 30 minutes.

939. Okay.

940. Cliff wants me to have a baby.

941. Well, you have a decision to make.

942. He's become obsessed with sex. He thinks it's gonna keep us together.

943. Listen, I really don't want to talk about that.

944. I just wanted to see you.

945. I think I can smell her perfume all the way to Cleveland.

946. It's hard keeping my mind on Leo Drummond and his people.

947. They'll be flying in first class and after a leisurely dinner,

948. they'll meet in some boardroom and discuss my total destruction.

949. Around the time I'm checking into Motel 6

950. they'll be sleeping soundly in their suites.

951. And they'll wake up fresh and rested and ready for war.

952. It's my deposition, but it's their turf.

953. Young Rudy Baylor, and just on time, too.

954. - Mr. Drummond. - Get this boy some coffee, Tyler.

955. - Jack Underhall. - Rudy Baylor.

956. Young lawyer's always a hungry lawyer. All these boys, claims, underwriters...

957. There must be a hundred years of legal experience gathered around the table.

958. Next to our lovely court reporter.

959. My staff has flunked the bar exam six times.

960. Now, Rudy, don't be intimidated by all these boys on this side of the table.

961. I guarantee you, you get them on the golf course, they fold like a cheap suit.

962. Let's see, let's see, what we got here.

963. I think maybe it's appropriate to start

964. with the corporate designee, Jack Underhall, right here.

965. I don't think so.

966. - I beg your pardon. - Well, you heard me.

967. I wanted to start with Jackie Lemancyzk, the claims handler.

968. I think it's best we start with Mr. Underhall.

969. All due respect, Mr. Drummond, this is my deposition.

970. I'm gonna call these witnesses in the order in which I see fit.

971. So I'd like to start with Jackie Lemancyzk.

972. Maybe we should just go call the Judge and...

973. Oh, I don't believe we have to get pugilistic this time of the morning.

974. I'm not meaning to be pugilistic.

975. We seem to be having a little problem

976. with Jackie Lemancyzk, this Polish woman.

977. What sort of problem?

978. She doesn't work here anymore.

979. Was she fired?

980. She resigned.

981. She resigned.

982. Well, where is she now?

983. Well, she's no longer working for our client

984. and we can't produce her as a witness, so let's move along.

985. All right, Russell Krokit.

986. Anybody in the room named Russell Krokit?

987. He's gone, too. Downsized.

988. Downsized? Well, what a coincidence.

989. Our client's going through a periodic downsizing.

990. Yeah, well that will happen, won't it?

991. How about Everett Lufkin, Vice-president of Claims?

992. Has he been downsized, too?

993. No, he's here.

994. You're Everett Lufkin?

995. My congratulations, Mr. Lufkin,

996. on your miraculous survival of the carnage of late

997. here at Great Benefit.

998. I'm curious.

999. About what?

1000. I'm just wondering.

1001. Do you even remember when you first sold out?

1002. You're an arrogant little pissant, aren't you?

1003. I advise you to mind your manners. You're in the big water now.

1004. Mind my manners?

1005. I come up here from Memphis

1006. to depose four people, two of whom are not here,

1007. and you tell me to mind my manners?

1008. Well, it's your dime. What's your call, son?

1009. I'm gonna depose him, Mr. Lufkin over there.

1010. Then I'm gonna pack up, I'm gonna go back to Memphis.

1011. So this is how the uninsured die.

1012. In a society filled with brilliant doctors, and state-of-the-art technology,

1013. it's obscene to let this boy just wither away and die.

1014. He was covered by an insurance policy

1015. that his mother paid good money for.

1016. It wasn't big money, but it was good money.

1017. I'm alone in this trial.

1018. I'm seriously outgunned and I'm scared, but I'm right.

1019. I sit here with this poor, suffering kid and I swear revenge.

1020. - Hello. - Rudy, it's me.

1021. What's wrong?

1022. - I need your help. - Where are you?

1023. - I'm at the store. - Okay, don't move, okay?

1024. I'm gonna be right there. All right.

1025. Rudy Baylor.

1026. She's in here.

1027. Thanks for coming.

1028. - What happened? - Come on, let's show him.

1029. I got you, Kelly. It's all right.

1030. Oh, Rudy, I'm so glad you called.

1031. Oh, you poor child.

1032. I'm gonna take care of you now.

1033. Don't you worry. Don't you worry. We'll manage just fine.

1034. All right. You know where I'll be if you need me.

1035. I do. I do.

1036. I tell myself I'll do whatever I have to do to get her out of this,

1037. because this guy is never gonna stop until he's killed her.

1038. Never.

1039. Hello.

1040. Now it's a wrongful death suit.

1041. - Gazillions. - Deck.

1042. I'm so sorry, Dot.

1043. Well, thank you so much for coming. I appreciate it.

1044. It'll be okay.

1045. Hey!

1046. For bugs?

1047. - Thank you. - You're welcome.

1048. - Thank you. - Enjoy your meal.

1049. This bugging device has got medium grade circuitry.

1050. It's a weak transmitter.

1051. Probably manufactured in Czechoslovakia.

1052. I don't think the cops or the Feds would place this.

1053. Somebody else is listening.

1054. Who else would be listening to us?

1055. I got a pretty good idea.

1056. - Rudy. - Yeah.

1057. Just checking in. You need anything from downtown?

1058. No. Hey, guess what? Guess who wants to settle?

1059. - Who? - Dot Black.

1060. Dot Black?

1061. I went by there today, to check up on her.

1062. I brought her a fruit cake. Yeah, and she said she just

1063. doesn't have the willpower to withstand a long trial and...

1064. How much?

1065. She said she'd take 175,000.

1066. I think we should take it.

1067. - We'll sleep on it. I'll see you tomorrow. - Okay.

1068. - All right, but I'm saying take it. - I know, I heard you.

1069. I'll think about it. All right. Bye.

1070. Son, this family has been through a hell of a lot.

1071. And I feel this woman wants to settle.

1072. I'll talk to her.

1073. You go ahead and call her. I'll wait here one more hour.

1074. Yeah, I'll get back to you, Mr. Drummond. Good day.

1075. Well, I'm sorry about the boy.

1076. Listen, my client wants to settle, Rudy.

1077. Let's say, Rudy, just for the sake of putting numbers on the board

1078. that the claim was covered,

1079. then my client should've paid out somewhere around 1 50, 1 75,000.

1080. If you say so.

1081. They bugged our phones.

1082. I do say so, and we will offer...

1083. - Guess we should... - Be prepared to offer...

1084. - ... call Judge Kipler. - ... that much right now.

1085. $175,000...

1086. I don't think so.

1087. - Why not? - I'll have it to you within seven days.

1088. I have an idea.

1089. - I don't think so. - A kind of a crazy idea.

1090. Jury tampering. I love it. I love it.

1091. Who's our biggest nightmare?

1092. The Judge gave us the names of 92 potential jurors.

1093. We investigated their backgrounds

1094. and we rated them with plus or minus numbers.

1095. - What do you want me to do? - All right, here we go.

1096. What? What?

1097. Any direct contact would, of course, be a serious offense.

1098. - What are we doing? - We're gonna do this thing.

1099. - Just do what I say. - Okay.

1100. - Hello. - Yeah, Rudy Baylor, please.

1101. - This is Rudy Baylor. - This is Billy Porter.

1102. - You stopped by the shop today. - Yes, Mr. Porter.

1103. - Thank you very much for calling back. - Well, what do you want?

1104. Yes, well, it's about the trial, the one you got a jury summons for?

1105. I'm one of the lawyers.

1106. Is this legal?

1107. Of course it's legal, Mr. Porter. Just don't go telling anybody.

1108. Look, I represent this lady whose son died of leukemia

1109. because the Great Benefit Insurance company

1110. wouldn't give them the money they needed for an operation.

1111. Well, that sounds awful. I had an aunt that had that same disease.

1112. Kept wasting away, and my uncle was trying...

1113. I'll do what I can.

1114. Well, yes, sir. Now, thank you, Mr. Porter, and you have a fine afternoon.

1115. What about the aunt?

1116. - Where'd the aunt come from? - I don't know.

1117. You told me to be sympathetic. I was trying to be sympathetic.

1118. I know, but don't elaborate. Get your coffee.

1119. - Let's go back up there. - I'm just trying to help.

1120. - Come on. - Right behind you.

1121. Ladies and gentlemen, what I'm about to ask

1122. is the most important question of the day.

1123. It's a simple question. It can be answered yes or no.

1124. Listen carefully.

1125. Have any of y'all been contacted about this case?

1126. - This is serious business. - Bingo.

1127. We need to know now. Let me ask it another way.

1128. Did any of you all have a conversation recently

1129. with either Mr. Rudy Baylor

1130. or directly behind him, Mr. Deck Schifflet?

1131. Objection, Your Honor! This is an outrage!

1132. What are you doing, Mr. Drummond?

1133. Your Honor, we have reason to believe that this panel's been tampered with!

1134. He's accusing me.

1135. I don't understand what you're doing, Mr. Drummond.

1136. Well, neither do I, Your Honor. Neither do I.

1137. Approach the bench, please.

1138. Your Honor, this panel's been tampered with.

1139. I want proof, Leo.

1140. I can't say without divulging confidential information.

1141. - You are just out of your mind. - You are acting rather bizarre, Leo.

1142. - I think I can prove it. - How?

1143. You accuse us of something like that? Tamper with... That's ridiculous.

1144. Just allow me to finish questioning the panel.

1145. - I think the truth will come forth. - Any objection, Mr. Baylor?

1146. - No, no objection. - Very well, proceed.

1147. All right.

1148. What in the Sam Hill is going on up there?

1149. Oh, it's just lawyer stuff.

1150. Mr. Porter, I want to ask you a direct question

1151. and I'd appreciate an honest response.

1152. You ask an honest question, I'll give you an honest answer.

1153. Fair enough.

1154. Did you, Mr. Porter, or did you not have a phone conversation

1155. - a few days ago with Mr. Rudy Baylor? - Hell, no.

1156. I thought you were gonna give me an honest answer.

1157. - I gave you an honest answer. - Are you sure, Mr. Porter?

1158. - I'm damn sure. - Mr. Porter, in a courthouse,

1159. in a courthouse in the United States,

1160. in a courthouse of justice in the state of Tennessee,

1161. I say you did not provide an honest answer!

1162. - Don't call me a liar! - Oh, you're a liar all right.

1163. - Mr. Drummond. - You son of a bitch!

1164. Mr. Porter, stop it!

1165. - Hey, get off of him! - Order in the court!

1166. - Get the hell... - He started it.

1167. Bailiff, remove Mr. Porter from this courtroom!

1168. Shit!

1169. Mr. Billy Porter, you are excused from the jury!

1170. Your Honor, I move to dismiss the entire panel, Your Honor.

1171. Denied.

1172. It's been tainted!

1173. Your shoe. You left it over there.

1174. Are we ready to proceed now with the jury selection, Mr. Drummond?

1175. I'm ready to proceed, Your Honor. We may proceed.

1176. Thank you.

1177. - We'll file it today. - He'll go crazy.

1178. He already is crazy.

1179. - He'll come after you. - I hope he does.

1180. This is that good processed turkey.

1181. Well, I gotta get back to court. I'm late. I gotta get back to the courthouse.

1182. What about your sandwich?

1183. Oh, well, I was gonna take that with me.

1184. - Oh, good, good. - I'll see you later.

1185. Okay.

1186. How'd it go?

1187. Served the papers on Cliff when he was on his way to lunch.

1188. He didn't take it too well.

1189. Said I was ready to rumble, he backed down.

1190. Hey, man, you better watch your back.

1191. All right. Thanks a lot, Butch. I appreciate it.

1192. Do you solemnly swear the testimony you are about to give in this cause

1193. will be the truth, the whole truth, and nothing but the truth, so help you God?

1194. - Yes, I do. - You may take the stand.

1195. - Please state your name for the record. - Mrs. Marvarine Black.

1196. Now, Mrs. Black, you are the mother of Donny Ray Black

1197. who recently died of acute myelocytic leukemia

1198. - because the defendant Great Benefit... - Objection. Leading.

1199. Sustained.

1200. Your son, Donny Ray, needed an operation.

1201. Objection. Leading.

1202. Sustained.

1203. Mrs. Black, did you purchase this medical policy

1204. because you were concerned about medical care for your son?

1205. Objection. I'm sorry, Your Honor. Leading.

1206. Mr. Baylor, why don't you show her the policy and ask her why she bought it?

1207. Okay.

1208. Mr. Baylor, you must ask to approach the witness.

1209. Sorry, Your Honor.

1210. - Permission to approach the witness. - You may.

1211. Take it easy. Take it easy.

1212. "Great Benefit. July 7th, 1996.

1213. "Re: Policy 7849909886."

1214. "Dear Mrs. Black.

1215. "On seven prior occasions this company has denied your claim in writing.

1216. "We now deny it for the eighth and final time.

1217. "You must be stupid, stupid, stupid.

1218. "Sincerely, Everett Lufkin, Vice-President, Claims Department."

1219. - Read it again. - Objection. Repetitious, Your Honor.

1220. Sustained.

1221. I tender the witness.

1222. - Mr. Drummond? - Your Honor.

1223. Please remove that exhibit.

1224. Now, Mrs. Black...

1225. Turn it off.

1226. Mrs. Black, why did you sue Great Benefit for $10 million?

1227. Is that all?

1228. - Beg your pardon? - I thought it was more than that.

1229. - Is that so? - Yes, sir.

1230. Your client has about a billion dollars and your client killed my son.

1231. Hell, I wanted to sue for a whole lot more.

1232. What would you do with the money,

1233. if this jury awards you $10 million?

1234. What you gonna do with the money?

1235. I'm gonna give it to the American Leukemia Society.

1236. Every cent.

1237. I don't want a dime of your stinking money.

1238. Realize you are under oath, Mrs. Black.

1239. - Approach the witness, Your Honor? - You may.

1240. Mrs. Black, I want you to read from the policy,

1241. page 16, Section K, Paragraph 14, ltem E,

1242. in which the insurance company has in plain English wording said

1243. that it will not pay for experimental procedures.

1244. Now, your lawsuit says that your son would've been saved

1245. if he had had a bone marrow transplant.

1246. Isn't it a fact, Mrs. Black,

1247. that there are only 7,000 bone marrow transplants

1248. performed a year in the United States,

1249. less than 200 in the state of Tennessee?

1250. Objection, Your Honor. He's leading the witness.

1251. This is cross-examination. Leading is allowed.

1252. Overruled. As to leading.

1253. So it was not covered by the policy.

1254. Now, Mrs. Black, who was it

1255. that first diagnosed your son's condition?

1256. Well, at the very beginning, our doctor, Dr. Page.

1257. - That would be your family physician? - Yes, sir, it would.

1258. - Is he a good doctor? - He's a very good doctor.

1259. And is it not true, Mrs. Black, that this capable truthful man

1260. told you repeatedly that a bone marrow transplant would do your son no good

1261. because of the type of leukemia he had?

1262. Well, no. No, he did not.

1263. He didn't say that. Not like that. To me.

1264. - Approach the witness, Your Honor? - You may.

1265. Mrs. Black, is this not Dr. Page's letterhead?

1266. And at the bottom there, is that not his signature?

1267. - He can't do that. - Yes, it is.

1268. - And is the letter not addressed to me? - Why?

1269. Because he can't introduce evidence that way. Plus, it's hearsay.

1270. Objection, Your Honor.

1271. A letter from the Blacks' family physician

1272. - to Mr. Drummond is inadmissible. - That is quite correct, Your Honor.

1273. And I'm not asking for this letter to be admitted into evidence.

1274. I'm simply asking that this witness be allowed to read the letter

1275. under Rule 612 of the Tennessee Rules of Evidence

1276. so her recollection can be refreshed, that's all.

1277. Mr. Baylor, what do you say?

1278. I don't know, Your Honor. I just object to this.

1279. And also, we were not furnished

1280. this letter in pretrial discovery!

1281. What do you say to that, Mr. Drummond?

1282. Your Honor, I had no idea this letter would be needed.

1283. I expect this lady to tell the truth about what her doctor told her.

1284. Anything else, Mr. Baylor?

1285. No.

1286. Mr. Drummond, I'm gonna give you a little latitude, but don't stray too far.

1287. Very well, Your Honor. Now, Mrs. Black, does that letter refresh your recollection

1288. as to whether or not Donny Ray's leukemia was the kind

1289. that could be helped by a bone marrow transplant?

1290. Well, see now, he's not a specialist.

1291. But he is a licensed, experienced and capable physician

1292. who lovingly told you time and time again

1293. what you quite understandably did not want to accept.

1294. That your son was going to die of leukemia

1295. despite the best efforts of medical science, is that not true?

1296. But he wasn't a specialist. I didn't believe him.

1297. Not only did you not believe him, ma'am,

1298. but you were less than truthful with me and with this jury moments ago

1299. when you told us under oath

1300. that Dr. Page never said that your son

1301. had the type of leukemia that could not be treated by a bone marrow transplant.

1302. I believe your exact words were, "He never said that. Not like that. To me."

1303. He wasn't a specialist.

1304. I just wanted Donny Ray to have the best medical treatment available.

1305. You'd do the same thing.

1306. Of course, ma'am. Of course.

1307. That'll be all, Your Honor.

1308. You may step down, Mrs. Black.

1309. - I didn't do very good, did I? - Oh, no, no, you did fine.

1310. It's all right. The jury can see it. The jury can see exactly what he's up to.

1311. The jury can see what he's up to. Don't worry about it.

1312. - I need a smoke. - I know you do.

1313. We're gonna get to that later.

1314. I hope he hasn't changed the locks.

1315. - Are you scared? - Yeah.

1316. Let's do it.

1317. What a pig.

1318. - I'm sorry. - Hurry, Kelly. Come on.

1319. There's more of my stuff in the closet.

1320. Hey, you can't take everything, Kelly.

1321. - Oh, no! - Hey! Hello!

1322. I'm home!

1323. So, what do you know? What do we have here?

1324. - What you two been doing in here, huh? - Hey, take it easy, all right?

1325. Come on, tell me! I'm your husband, remember that?

1326. - Hey, take it easy, buddy. - You shut up!

1327. - Hey, listen, buddy, all right? Listen. - That's enough.

1328. Take it easy. Take it easy.

1329. You hurt me, baby. You hurt me so bad.

1330. Why are you doing this to me?

1331. No! Cliff!

1332. No!

1333. Cliff!

1334. Rudy! Rudy!

1335. - Cliff, you idiot! What are you doing? - You see what you did, Kelly?

1336. See what you did. Is this what you wanted?

1337. It's not my fault! I love you! I love you!

1338. Rudy!

1339. Stop it, Rudy! Stop.

1340. - Give me the bat and leave. - What?

1341. Give me the bat and leave. You were not here tonight.

1342. Give me the bat.

1343. Go, Rudy. You were not here tonight.

1344. - He's finally killed her. - No, it's him. He's dead.

1345. - You sure? - Yes, sir.

1346. How'd it happen? I don't know, but wait till the Riker family...

1347. They say, when you commit a murder, you make at least 25 mistakes

1348. and later you're lucky if you remember five of them.

1349. It was self-defense, but I can't get past the fact that he's dead,

1350. and the mistakes are piling up in my mind so fast I can't think.

1351. This way, ma'am.

1352. But Kelly knew. She knew what to do. She knew it was time.

1353. With everything that was happening and all that was at stake,

1354. her first thought was for my safety.

1355. And I left her in there all alone.

1356. Damn it! God damn you, Kelly!

1357. What the hell's going on here? What the hell did you do?

1358. You killed my son! God damn you!

1359. Excuse me, I'm her lawyer.

1360. I insist on being here while she's being questioned.

1361. - This is your attorney? - Yes, sir.

1362. I want her released to my custody.

1363. I can't do that.

1364. I don't know what kind of lawyer you are, but we got a dead body here

1365. - and bond needs to be set by a judge. - I'm going to jail?

1366. - Can we arrange for a private cell? - Look, asshole, I don't run the jail.

1367. You got a better way of doing things, then you need to talk to the jailer.

1368. And they love lawyers down there, right?

1369. Look, if your lawyer here is worth his salt,

1370. you'll be out of here sometime tomorrow,

1371. if you can post bond, okay?

1372. - You got five. - Thank you.

1373. They're watching us through that window there

1374. and this room is probably bugged, so just be careful what you say.

1375. What does "manslaughter" mean?

1376. It's murder without the element of intent.

1377. How much time could I get?

1378. No, no, no, you have to be convicted first. I'm not gonna let that happen.

1379. My son has a football game tomorrow night.

1380. That's not gonna happen.

1381. Oh, really? Who does he play for?

1382. Memphis State.

1383. Cross your wrists behind you, please, ma'am.

1384. This way, ma'am.

1385. Mr. Lufkin, you are the Vice-President of Claims at Great Benefit, are you not?

1386. - Yes, I am. - Approach the witness, Your Honor?

1387. You may.

1388. Do you recognize this? Go on.

1389. Read that to the jury.

1390. "Dear Mrs. Black. On seven prior occasions

1391. "this company has denied your claim in writing.

1392. "We now deny it for the eighth and final time.

1393. "You must be stupid, stupid, stupid.

1394. "Sincerely, Everett Lufkin Vice-President, Claims."

1395. That's you.

1396. Yes.

1397. How do you explain that?

1398. It was a difficult time for me personally. I was under a lot of stress.

1399. We had denied this claim seven times before.

1400. I was trying to be emphatic. I snapped.

1401. I regret having written the letter, and I apologize.

1402. Don't you think it's a little late for an apology?

1403. - Maybe. - Maybe?

1404. The boy is dead, isn't he?

1405. Yes.

1406. Now, Mr. Lufkin, who is Jackie Lemancyzk?

1407. Jackie Lemancyzk is a former claims handler.

1408. - And did she work in your department? - Yes.

1409. And when did she stop working for Great Benefit?

1410. - I don't remember the date. - How about October 30th?

1411. Sounds close.

1412. And wasn't that just two days before she was scheduled

1413. to give a deposition in this case?

1414. I really don't remember.

1415. I'd like to refresh the witness's recollection under Rule 612.

1416. - October 30th. - Apparently.

1417. And that was just two days before she was scheduled

1418. - to give a deposition in this matter. - I guess so.

1419. And she was the person responsible

1420. for handling Donny Ray Black's claim, was she not?

1421. - That's correct. - And you fired her.

1422. Of course not.

1423. - Well, how did you get rid of her? - She resigned.

1424. It's right here in the letter you just gave me.

1425. Why did she resign?

1426. "I hereby resign for personal reasons."

1427. - So it was her idea to leave her job? - That's what it says.

1428. - I have nothing further. - You may step down, sir.

1429. Hello.

1430. Hi, I'm Jackie Lemancyzk's brother,

1431. James.

1432. - Is it possible to see her? - James Lemancyzk?

1433. - Yes. - One minute.

1434. All rise.

1435. Let me explain, Ms. Lemancyzk. I'm really not your brother.

1436. Rudy. Good.

1437. I'd like you to meet Jackie Lemancyzk.

1438. This is Jackie Lemancyzk.

1439. Where she goes, Carl goes.

1440. This is my partner Rudy S. Baylor.

1441. Just tell him what you told me.

1442. Ms. Lemancyzk. It's a pleasure to meet you.

1443. - Is it all right if I sit down? - Sure. Sure.

1444. All right, Ms. Lemancyzk.

1445. Let's talk about the Black file. It was assigned to you?

1446. Yes, that's correct. The initial claim from Mrs. Black was assigned to me.

1447. Pursuant to company policy at the time, I sent her a letter of denial.

1448. - Why? - Why?

1449. Because all claims were initially denied.

1450. - All claims? - All claims.

1451. Okay, this is how it works.

1452. The policy is sold door-to-door in the poorer neighborhoods,

1453. paid in cash each week.

1454. The claim comes in and is assigned to a handler.

1455. It's basically a low-level paper-pusher.

1456. Anyway, the handler reviews it

1457. and immediately sends a letter to the insured denying the claim.

1458. The claim's handler then sends the file over to Underwriting.

1459. Underwriting sends a memo back to Claims saying,

1460. "Don't pay this until you hear from us."

1461. Now, what you should keep in mind

1462. is that even though all these people work for this big company

1463. and they all work in the same building, they don't know each other,

1464. nor do they know what the other department is up to.

1465. Now this is very intentional.

1466. Departments are kept at war with each other.

1467. And, meanwhile there's the client.

1468. And they're getting all these letters

1469. some from Claims, some from Underwriting,

1470. and most people give up.

1471. And this, of course, is intended.

1472. Your next witness, Mr. Baylor.

1473. Plaintiff calls Jackie Lemancyzk.

1474. - What did he say? - You're kidding.

1475. Objection, Your Honor. Approach the bench?

1476. You may.

1477. This is a complete surprise, Your Honor.

1478. Why? She's listed as a potential witness.

1479. We have the right to be forewarned. When did you find her?

1480. - I didn't know she was lost. - It's a fair question, Mr. Baylor.

1481. - Well, it's my first trial, Your Honor. - That's not good enough.

1482. It is a matter of fairness, Your Honor.

1483. We have the right to be notified about your witness.

1484. - I agree. - You're telling me she can't testify?

1485. She's listed in the pretrial order, Your Honor.

1486. Pursuant to Rule 26.06, we have the right to call her as a witness.

1487. Objection overruled.

1488. Go memorize.

1489. - State your name for the record. - Jackie Lemancyzk.

1490. Miss Lemancyzk, how long did you work for Great Benefit?

1491. - Six years. - And when did your employment end?

1492. - October 30th. - How did it end?

1493. I was fired.

1494. - You mean you did not resign? - No, I was fired.

1495. - Approach the witness, Your Honor? - You may.

1496. I am baffled, Miss Lemancyzk, because I have this letter here and it says

1497. - that you quit for personal reasons. - The letter is a lie.

1498. I was fired so the company could claim that I no longer worked there.

1499. Would you please point out the man in the courtroom

1500. who made you write this letter?

1501. Jack Underhall.

1502. He told me I was leaving immediately

1503. and I had two choices.

1504. I could call it a firing and leave with nothing or I could write that letter,

1505. call it resignation and the company would give me

1506. $10,000 in cash to keep quiet.

1507. And I had to make that decision right there in his presence.

1508. Go on.

1509. I took the cash

1510. and I also signed a letter saying that I would never discuss

1511. - any of my claims files with anybody. - Including the Black file?

1512. Specifically the Black file.

1513. So you knew that that claim should've been paid.

1514. Everybody knew. But the company was playing the odds.

1515. What odds?

1516. The odds that the insured would not consult a lawyer.

1517. Now, during that time

1518. you were a senior claims examiner?

1519. Yes, that's correct.

1520. And during that time, was there ever an occasion

1521. when you were given instructions regarding

1522. how you should handle claims?

1523. Deny all claims for a year,

1524. add up the money saved,

1525. deduct the amount spent on quick court settlements

1526. and there's a pot of gold left.

1527. - Approach the clerk, Your Honor? - You may.

1528. Thank you. Number 6, please.

1529. Here's what has heretofore been marked as defense exhibit number 6.

1530. You recognize this?

1531. Yes, it's a Great Benefit's company claims manual.

1532. Would you do me a favor and just flip over to section U, please?

1533. There is no section U.

1534. But do you remember a section U when you were a senior claims examiner?

1535. Yes, I do.

1536. Section U was an executive memorandum

1537. - in the senior examiner's manual. - Thank you.

1538. Your Honor, this is Jackie Lemancyzk's actual senior claims manual

1539. and within it there is an executive memorandum entitled section U.

1540. I ask that I might approach this witness to read...

1541. Objection, Your Honor. Approach the bench?

1542. Your Honor, we were not given a complete manual by the defense.

1543. Your Honor, this document contains executive memoranda

1544. that are stolen work papers, and may not be admitted.

1545. - May not be admitted? - Can you prove this, Leo?

1546. Your Honor, I ask that you instruct my colleague here

1547. not to read from, nor to make reference to,

1548. any suspect word product till I've had the opportunity to assess it.

1549. I don't understand. How is this not admissible?

1550. It was not proffered at the correct time

1551. - nor do we know how it was obtained. - I just found out about this last night.

1552. Okay. Okay. Assuming that I can't get this in now,

1553. do you have any more questions for the witness?

1554. No, Your Honor.

1555. You may cross-examine, Mr. Drummond.

1556. Thank you.

1557. Is it true, Miss Lemancyzk,

1558. that you have recently been committed to an institution for various problems?

1559. I was not committed.

1560. I am suffering from alcoholism and depression

1561. and I voluntarily checked into a facility.

1562. I was supposed to be covered

1563. by my group policy at Great Benefit

1564. and they, of course, are denying my claim.

1565. Is that why you're here, Miss Lemancyzk?

1566. Because you're angry with Great Benefit? Miss Lemancyzk?

1567. I hate Great Benefit and most of the worms that work there.

1568. Did you feel Mr. Lufkin was a worm when you were sleeping with him?

1569. Objection!

1570. Your Honor, Mr. Drummond might find this fun to talk about,

1571. but, this is not relevant at all.

1572. Oh, this is no fun for me.

1573. Overruled. Let's see where this takes us.

1574. You admit to having an affair with Mr. Lufkin?

1575. Miss Lemancyzk?

1576. As long as I had sex with certain executives at Great Benefit,

1577. my pay was increased and I was promoted.

1578. - When I stopped, I was demoted. - Miss Lemancyzk,

1579. as an employee of Great Benefit you promised not to disclose

1580. confidential private claims information. Yes?

1581. Yes.

1582. In fact, you testified that you sealed that promise

1583. by demand of payment for $10,000, didn't you?

1584. - That payment was not my idea. - But you accepted it, didn't you?

1585. You put it right in your pocketbook.

1586. Even though, in your mind, you never intended to keep that promise.

1587. In fact, you were very angry at Great Benefit and Mr. Lufkin, weren't you?

1588. You know, they preyed on me

1589. because I was broke and I was single and I had two kids!

1590. So you told him you were gonna go to his wife,

1591. go to the newspapers and that $10,000,

1592. that was just a piece of blackmail, wasn't it?

1593. A way to extort money from the company you hated, isn't that right?

1594. - No, that's not right. - In fact, your testimony here today

1595. is just a lie! You stole company work papers,

1596. confidential reports as blackmail for revenge!

1597. Hell hath no fury as what, Miss Lemancyzk?

1598. A woman scorned.

1599. Your Honor, I move that all documents provided the plaintiff

1600. by Miss Jackie Lemancyzk be deemed stolen work papers

1601. and struck from these proceedings.

1602. Based on the evidence presently before the court

1603. these documents are inadmissible.

1604. - No further questions. - Thank you, Mr. Drummond.

1605. - Mr. Baylor? - Thank you, Your Honor.

1606. You may step down, Miss Lemancyzk.

1607. I'm sorry.

1608. Hello.

1609. Hi, this is Deck Schifflet. I need to speak to Big Rhino.

1610. - Can you connect me? - Big Rhino? Just a second.

1611. Okay.

1612. - Hello. - Hey, Boss, it's Deck.

1613. - Hey, Deck, how you doing? - Good, how are you?

1614. - I'm cool. - Are you here?

1615. - Well, I'm here and there. - Oh, yeah, here and there.

1616. Well, listen, I got a stolen evidence situation.

1617. Okay, stolen evidence, let me see...

1618. - DeSoto case. - DeSoto?

1619. Carmine DeSoto. You remember him?

1620. - Club Ruby. - Where do I find that?

1621. Around '92, you'll find it, let's see, 650-something, Southwest Second.

1622. Boss, you're a lifesaver.

1623. - '92? - Yeah, Club Ruby case.

1624. - '92. - Carmine DeSoto...

1625. - Carmine DeSoto, Club Ruby. - Club Ruby.

1626. Through the appellate court.

1627. Yeah, yeah, yeah, it kind of rings a bell.

1628. I got it. And from Bruiser of all people.

1629. Bruiser? I thought you didn't know where Bruiser was.

1630. I don't.

1631. But I got an emergency contact number.

1632. I call them, they get me in touch with him.

1633. Look, Rudy, nobody knows more than Bruiser about stolen evidence.

1634. You might say it's his stock and trade.

1635. - Hello. - Mr. Rudy Baylor?

1636. - Yes. - This is the Shelby County D.A.

1637. If you could come to the courthouse tonight,

1638. - I'd like to discuss the Kelly Riker case. - Sure.

1639. Come to Room 6.

1640. There's an advantage to dealing with pimps and thieves.

1641. In the case of Carmine DeSoto versus the Club Ruby

1642. there are reams of stolen evidence.

1643. Now, Bruiser worked on this stuff himself.

1644. - Not now. I gotta go. - You gotta go?

1645. You got the CEO of Great Benefit coming in tomorrow.

1646. We gotta nail this guy! Come on!

1647. - Good luck, Kelly. - Thanks.

1648. I met with the D.A. She's not gonna prosecute.

1649. Said she'd never get a conviction. It was self-defense, Kelly.

1650. The plaintiff would like to call Wilfred Keeley to the stand.

1651. Raise your right hand, please.

1652. Do you solemnly swear that the testimony you are about to give

1653. in this cause will be the truth, the whole truth

1654. and nothing but the truth, so help you God?

1655. - I do. - You may take the stand.

1656. - State your name for the record. - Wilfred Keeley.

1657. May I approach the witness, Your Honor?

1658. You may.

1659. Mr. Keeley, this Great Benefit brochure, is that you? Is that your name?

1660. - Yes. - And what do those initials stand for?

1661. CEO?

1662. Yeah, what do they stand for? What does CEO mean?

1663. - Chief Executive Officer. - Chief Executive Officer. Thank you.

1664. So, you're the guy.

1665. You're the main guy, you're the cheese. The buck stops with you.

1666. - You could say that. Yes. - Yeah. Okay. Thank you.

1667. Your Honor, I'd like to turn the questioning of Mr. Keeley

1668. over to my partner, Rudy Baylor.

1669. What are you, out of your mind?

1670. - You don't have a license! - I didn't have a choice!

1671. What are you doing? You're late.

1672. Good morning, Your Honor. I'm sorry I'm late, sir.

1673. - Approach the witness, Your Honor? - You may.

1674. This is the claims manual that was given to me by Jackie Lemancyzk.

1675. Objection, Your Honor. Stolen work papers. Inadmissible.

1676. - You ruled on this. - Sustained.

1677. May we approach?

1678. I thought this matter was already settled, Your Honor.

1679. Your Honor, I have just this morning

1680. found a case that is controlling in this factual situation.

1681. What do you have?

1682. If you'll just take a look at this ruling.

1683. - It's Club Ruby v. Carmine DeSoto. - Here.

1684. A copy for Your Honor and one for Mr. Drummond.

1685. Number 585, Southwest Second, page 431.

1686. It was argued by Bruiser... By J. Lyman Stone,

1687. and it shows very clearly that stolen documents

1688. are in fact admissible if the lawyers played no part in the theft.

1689. Well, according to these head notes, this case would overrule your objection.

1690. Sorry, Leo.

1691. Oh, I'm sure you are, Your Honor. But note my strong objection.

1692. - Objection noted. - May I approach?

1693. Do so.

1694. Your Honor, I'm sorry.

1695. Excuse the interruption, Mr. Keeley.

1696. We were about to talk about the Great Benefit claims manual.

1697. Is that a complete Great Benefit claims manual, sir?

1698. - Yes. - Does it have a Section U?

1699. It has a Section U in it.

1700. Well, let's talk about this mysterious Section U.

1701. Why don't we explain it to the jury? Take a look at it.

1702. Just read paragraph three.

1703. "Claim handlers are directed to deny all claims

1704. "within three days of receipt of claim. No exceptions."

1705. Now, how do you explain this section U?

1706. Well, sometimes we get some frivolous and fraudulent claims in our business.

1707. And sometimes we have to use this kind of language

1708. to focus in on the legitimate and more needy claims.

1709. Mr. Keeley, do you honestly expect this court to believe that explanation?

1710. Well, this chapter merely denotes in-house processing guidelines.

1711. In-house processing guidelines? No, Mr. Keeley. No, it does not!

1712. - Section U does a lot more than that. - I don't think it does that, son.

1713. Mr. Keeley, doesn't it explain precisely

1714. how claims should be routed and shuffled and rerouted,

1715. anything to avoid payment?

1716. - I admit nothing. - Your Honor, approach the witness?

1717. You may.

1718. Now, Mr. Keeley,

1719. how many policies did Great Benefit have in effect in the year 1995?

1720. I don't know. But let's see.

1721. Does the figure 98,000 sound correct, give or take a few?

1722. Maybe. That could be right, yeah.

1723. Thank you.

1724. Now, of these policies how many claims were filed?

1725. Well, I don't know that.

1726. Does the figure of 1 1,400 sound correct to you, give or take a few?

1727. That's about right.

1728. But, I'd have to... I'd have to verify it, of course.

1729. I see, so the information that I want is right there in that book?

1730. - Yes. - Can you tell the jury,

1731. of the eleven some-odd thousand claims filed, how many were denied?

1732. I don't think I could. That would take more time.

1733. You've had two months, Mr. Keeley. Now answer the question.

1734. Well, I... I don't think...

1735. 9,141.

1736. 1 1,462 filed,

1737. 9,141 denied.

1738. Your Honor, I have yet another document.

1739. This is a report from Great Benefit's medical committee.

1740. Request permission under previous precedent

1741. - to present to Mr. Keeley. - Same objection, Your Honor.

1742. - Overruled. Objection noted. - Thank you.

1743. Mr. Keeley, that is a report from Great Benefit's

1744. own medical committee which you chaired.

1745. Would you please read from line 18?

1746. "Since bone marrow transplants have become standard procedure,

1747. "Great Benefit would be financially justified

1748. "in investing in bone marrow clinics."

1749. - Approach the witness, Your Honor? - You may.

1750. Thank you.

1751. Here you go.

1752. - A little louder. - Objection, Your Honor. Repetitious.

1753. Overruled.

1754. I want the jury to hear this.

1755. "Since bone marrow transplants have become standard procedure,

1756. "Great Benefit would be financially justified

1757. "in investing in bone marrow clinics."

1758. "Financially justified."

1759. That's what it's all about at Great Benefit, isn't it?

1760. - Tender the witness. - Mr. Drummond.

1761. No questions. We rest on our objections.

1762. - You are excused, Mr. Keeley. - Thank you.

1763. Rudy! Come on, get up.

1764. - Come on, it's time. Let's go. - What?

1765. Come on. Come on.

1766. What will giving a judgment of $10 million accomplish?

1767. All insurance company premiums will spin out of reach,

1768. and it will pave the way for government-controlled health coverage!

1769. Yours is a grave responsibility.

1770. Be wise, be careful and be just.

1771. Be just.

1772. Thank you, Your Honor.

1773. - Mr. Baylor, your rebuttal. - Thank you, Your Honor.

1774. Ladies and gentlemen of the jury.

1775. When I think of Donny Ray Black

1776. gasping for his last breath of air, slowly dying,

1777. I am disgusted with myself,

1778. and with the entire legal profession that could not save him.

1779. I don't even feel good enough about myself as a lawyer

1780. to make my own summation.

1781. So I thought I'd let Donny Ray do that.

1782. Exhibit 16.

1783. I weigh 110 pounds.

1784. Eleven months ago, I weighed 160.

1785. The leukemia was detected in plenty of time.

1786. I was in the hospital being treated when the doctors realized

1787. that the only thing that could save my life

1788. would be a bone marrow transplant.

1789. So I got released from the hospital

1790. 'cause my family couldn't afford to pay the bill for what they had recommended.

1791. Great Benefit Insurance denied our claim.

1792. It's okay.

1793. If I'd had a bone marrow transplant I would've had a 90% chance of living.

1794. I hope that you are astonished as I am

1795. at the lengths to which a wealthy insurance company like the defendant

1796. will go to take money from a low-income family and then keep it,

1797. by denying a legitimate claim.

1798. It's no wonder they spend so much money on their lawyers

1799. and their lobbyists and their public relations machine

1800. to convince us we need tort reform,

1801. that we need to put an end to punitive damages.

1802. I'm asking you, the jury,

1803. just

1804. do what you think is right in your hearts.

1805. If you don't punish Great Benefit,

1806. you could be their next victim.

1807. That's it.

1808. Don't be nervous.

1809. Has the jury reached a verdict?

1810. Yes, we have, Your Honor.

1811. Is it written on paper according to my instructions?

1812. - Yes, sir. - Please read the verdict.

1813. "We, the jury, find for the plaintiff

1814. "and award actual damages in the amount of $150,000.

1815. "And we, the jury, find for the plaintiff

1816. "and award punitive damages in the amount of $50 million."

1817. All rise.

1818. These people were trying to hide things, trying to get away with something,

1819. and they were... And they got caught at it.

1820. Another remarkable part of the story,

1821. the lead attorney on the case, Rudy Baylor, was trying his first case.

1822. That's a staggering verdict, I think, by anybody's estimation.

1823. It's certainly one of the largest and probably...

1824. - Not bad for a yard boy. - Oh, it wasn't that difficult, really.

1825. We just had a great jury is what we had

1826. and the facts just fell into place.

1827. $50 million in punitive damages...

1828. - $50 million? How much do you get? - Yeah.

1829. Well, you get right to the point, don't you?

1830. - Oh, sorry! That's not what I meant. - I know you didn't.

1831. We get one third, but the money's not in the bank yet.

1832. - I'll see you later. - You're gonna leave this girl all alone?

1833. Not for long.

1834. Rudy. Rudy.

1835. I've decided I'm gonna put your name in my will.

1836. You know what? You are just too kind to me, Miss Birdie.

1837. Hot off the news wire.

1838. "Mr. Wilfred Keeley, CEO of Great Benefit,

1839. "was detained yesterday afternoon at JFK

1840. "just after boarding a flight bound for Heathrow.

1841. "Traveling with his wife, they claimed to be sneaking away for a quick holiday.

1842. "However, they could not produce the name of a hotel anywhere in Europe...

1843. At which they were expected.

1844. At 5:00 p.m. today, insurance company Great Benefit filed for protection

1845. under the bankruptcy code in federal court in Cleveland.

1846. Many states are now investigating Great Benefit

1847. and a number of class action lawsuits have been filed.

1848. For CNN, Dick Redman reporting.

1849. - Hello. - Rudy?

1850. Leo Drummond here.

1851. It appears the company's been looted.

1852. I'm sorry, Rudy. I wanted you to get every penny of that money.

1853. Everybody loses on this one.

1854. Wanted you to know.

1855. Thank you, Mr. Drummond.

1856. Great Benefit's like a bad slot machine, it never pays off.

1857. We should've taken the 175,000. What the hell were we thinking?

1858. Just got all twisted, didn't it? This legal profession.

1859. Every lawyer in America is talking about me right now.

1860. But that doesn't exactly make me feel like a member of the legal community.

1861. I might be able to go on practicing law if I was working with my whole heart,

1862. but I can't do that and cover Kelly.

1863. And she's gonna need a lot of cover for a while.

1864. I still love the law. I'll always love it.

1865. But maybe I should be teaching it

1866. instead of practicing it out here in the world.

1867. I need time to work it out.

1868. Great Benefit's gone belly up.

1869. Barring a miracle way off in the distance, we won't get a dime.

1870. - God. - You put them out of business, Dot.

1871. One little woman from Memphis, Tennessee

1872. bankrupted them sons of bitches?

1873. I'm gonna go to Donny Ray's grave tomorrow and tell him all about it.

1874. So I guess Kelly and I will be taking off first thing in the morning.

1875. We made history, Rudy.

1876. You know that?

1877. We can always brag.

1878. Bye.

1879. There's no doubt about it, I'm hot.

1880. In fact, I'm so hot after this case,

1881. there's no place for me to go but down.

1882. See you.

1883. Every client I ever have will expect this, the same magic, nothing less.

1884. And I could probably give it to them if it didn't matter how I did it.

1885. And then one morning I'd wake up and find that I'd become Leo Drummond.

1886. Now you give me a call when you pass the bar exam.

1887. Yeah, piece of cake!

1888. Every lawyer, at least once in every case,

1889. feels himself crossing a line he doesn't really mean to cross.

1890. It just happens.

1891. And if you cross it enough times, it disappears forever

1892. and then you're nothing but another lawyer joke.

1893. Just another shark in the dirty water.