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Previously on The Rainmaker. What do you need to win?
We need to find Jackie LaMancher.
Jackie?
Jackie, wait! I represent Don Black, Donny Ray Black's mother, I believe.
I'm sorry, I can't help you.
Get away from this place, Barry. Get away from people like Leo.
Like me. That guy was our best chance winning this case.
I gave you a gun and a guy ended up dead.
That's what friends do for each other. We're dropping the case. That's all you
need to know. You can't do that. It's actually not your decision.
Excuse me? Dot did sign with Jaylon, so she fired you.
She signed with me.
You think you have what it takes to go it alone?
I know he does.
Look, we're gonna be good.
Okay, we have a good case.
This is wrong.
His nurse is a serial killer. We can't prove that in court. We don't have a
witness. We don't have a record.
We can't prove it to a jury.
Drummond will move for sanctions. Judge will grant it and we will lose.
They knew about it. The hospital knew about it. They covered it up. You can't
prove that.
It's the truth.
The truth doesn't matter.
How can you say that?
Without Jackie's testimony, whatever you say in your opening statement, Rudy,
you have to be able to prove a trial.
We had the tissue committee files. The files only proved that Jackie suspected
that Melvin was killing his patients, okay? The committee, they didn't believe
her. Now she has the proof. She is the proof. Yes, but we don't have her.
Yeah, but it wasn't just negligence, Zach.
Just listen to me now. Please, listen to me. Listen.
Your opening statement.
It is a contract with the jury that you're going to prove what you're
If you break that promise, we're done.
I wish Bruiser was here.
Rudy, you know I dreamed about being a lawyer since I was ten years old.
You know what I see when I look at you?
Come on, man.
The man I always wanted to be.
You can do this.
You're all we've got.
You know what? Give me a second.
Let me have that.
Not let you walk in there holding a cardboard box.
I'll get you to go out to breakfast.
I can't eat.
First time for everything.
You ready to take the trash out?
You bet.
What are you doing?
Come on.
I didn't pass the bar, so I can't cross the bar.
Look, I'm going to be right here.
I'm going to be right here behind you, all right?
I know.
You two are friends.
Of course.
Been arguing for days.
What do you decide to do?
Claim we filed this for medical malpractice. We can't prove murder, not
more evidence.
But, really, you're a call.
You're in the client.
And you're my lawyer.
There's one thing I've learned about you, Rudy.
It's that you always do the right thing.
What are we here to do today?
Leave his blood on the floor.
Our little girl's growing up, Brad.
Bill.
Bill. Glad you could make it.
Sarah. Good morning, Mr. Keel. Nice to see you.
All rise.
The court of common pleas.
Ninth Judicial Circuit now in session.
The Honorable Liza Murdoch presiding.
Good morning, everyone.
Morning, Your Honor. Morning, Judge.
Lovely day to get started.
The man is dead, Mr. Drummond. Let's act accordingly.
Of course, Your Honor. Understood.
Let's bring the jury in.
Why are you getting so upset?
Because I should be in that courtroom right now.
I made a judgment call.
Oh, yeah? Well, your judgment got you a prison sentence.
Yeah, my judgment put you through law school.
We have a search warrant for these premises. You've got to be kidding.
Nice to see you again, Miss Stone.
Anyone else in the building?
Just us chickens.
You guys are unreal.
Good morning. My name is Rudy Baylor.
It was my first trial.
It was just a few months ago that I was still in law school.
That's where I met Dot Black.
Who was running a free legal clinic?
Mostly small claims matters, but Dot came with a different kind of problem.
She was distraught because her son, Donnie Ray, had died.
in the care of North City Hospital, subsidiary of Great Benefit. Now, they
he died of a drug overdose.
I will prove to you that Donny Ray was clean and had been for over a year.
I will prove that the hospital and its staff were negligent in caring for Donny
Ray.
I will prove and that
What's wrong?
My opening statement, Your Honor. Mr. Baylor?
It's a contract with the jury, right?
I lied.
It's not just that the hospital was negligent.
No, it was much worse than that. So much worse.
A nurse at North City Hospital murdered my client's son. Mr. Baylor.
Shouldn't we object?
His name is Melvin.
Mr.
Baylor. He murdered Donny Ray Black. And that man right there, CEO Wilford
Keeley, and several of his executives knew about it, and they covered it up.
Baylor, that's enough. Another nurse.
Jackie Lemanshig, she's a suspected prisoner. Mr. Baylor, did you not hear
gavel? We only need to preserve our objections for the administration. Don't
bother killing your enemy when he's busy committing suicide.
Donny Ray Black was murdered. They knew about it. Mr. Baylor, I'm warning you.
They covered it up.
That is enough, Mr. Baylor. Did you not hear the gavel? And that is the truth.
Counsel, in my chambers now.
My first... Your first trial was a case against a baker who delivered the wrong
wedding cake.
Your first case, Mr. Baylor, is against a major corporation. I can only imagine
the stress you're under.
But that said, your performance in there was utterly beneath the dignity of this
court. When I banged that gavel, you shut up.
During the hearing on your motion to compel, Judge Kipler invited you to
your complaint.
You and your then co -counsel, Miss Stone, declined.
Yes, well, new evidence has come to light, Your Honor.
Involving what you allege to be multiple murders. And you didn't immediately
produce it to opposing counsel and alert this court?
Oh, instead, you ambushed us all in your opening. Just what, in God's name, is
this new evidence?
It's, um... I don't have it just yet.
Go ahead, Leo.
Because, frankly, I'm out of words.
We've been working under the assumption that we're defending against a garden
variety medical malpractice claim. To be blindsided and have my client defamed
in front of the jury based on some vague reference to evidence, we haven't seen
that Mr. Baylor concedes he doesn't even have his amateur hour at best.
If there is any such evidence, he has to produce it here and now.
Otherwise, based on this disgraceful conduct, not to mention the irreparable
prejudice to my client.
I move that you dismiss this action in its entirety as a sanction under Rule
It's hard to argue.
Mr. Baylor, would you like to try?
Respectfully, Your Honor.
I may be new at this, but I believe you need to make an explicit finding of bad
faith on my part to dismiss the case on those grounds. I'm prepared to submit
the oath required under Rule 40, I too, that I'm not doing this for an improper
purpose.
All I'm asking for is 48 hours.
to produce the evidence in support of the new claim. Your Honor, Mr. Drummond
and his associates, they may not believe that a trial is about the truth.
Please.
I do.
I think you do, too.
You'll know what I believe when I render a decision.
I'll give you 24 hours. Your Honor! I'm sending the jury home. You have one
shot.
Mr. Baylor.
One.
Thank you, Ron.
Detective!
I need to talk to her.
I got my suitcase, got my car, and I got my place. And I had a home, but it was
never mine.
I went through the motions all night of time. And I burned down, burned it all
down. I told him, five minutes.
He'll be here, Your Honor.
And who are you?
Jack Shiflett, power lawyer.
Power lawyer?
Yes, no, it's power law. It is like paralegal, except I went to law school.
I just didn't pass the bar.
I honestly think I'm not a wonderful test taker.
Truth is, he's here, Your Honor.
Rudy Baylor.
Mr. Baylor, I trust you have the new evidence to support your amended
Yes, Your Honor.
We'd like to call Jackie LeMangic to the stand.
Leo, what the hell?
Your Honor, we object to the surprised witness and move to exclude her
testimony. Your Honor, Ms. Pomanchik has been in protective custody because
Melvin Pritchard, the nurse that we believe killed Donnie Ray Black,
her and is still at large.
Objection prejudicial.
There's no jury here, Mr. Drummond.
I'll question the witness myself.
Ms. Lomanchik, the plaintiff alleges that the executives of Great Benefit
conspired to cover up and conceal a murder.
Do you have evidence to support that claim?
I don't have evidence of a murder.
I have evidence of 15 murders.
And what is this evidence?
I have the Narpen's data, you son of a bitch.
Objection, Your Honor. Those files are the property of my client.
Hang on.
What is a Narpense?
The Narpense machine dispenses narcotics.
Donny Ray was one of 15 mysterious overdoses at North City, who all had one
thing in common.
Melvin Pritchard was the ER nurse.
On each occasion, he had ordered unauthorized morphine from the machine
immediately canceled the transaction.
What do you mean he canceled?
Well, if you cancel it, the drawer closes after three seconds.
That's enough time to remove the medication.
Objection. Speculation. That's your evidence. A nurse canceled some morphing
orders? Your Honor, two or three times. It was a coincidence, but 15?
How did you get these files?
Well, after I was fired, I went back to the hospital while my ID was still
active, and I downloaded them.
Your Honor, this witness, by her own testimony, has committed theft of
property and violated HIPAA no less than 15 times.
Evidence illegally obtained is inadmissible.
Okay. I've heard enough, thank you, Miss Lomanchik.
Wait, wait, that's it?
Your Honor, I'm entitled to a ruling on my objection.
Yes, you are.
Objection sustained.
What on what?
But the motion to dismiss is denied.
Your Honor.
I'll allow the trial to proceed on both the plaintiff's claims. However, I have
no choice but to exclude both the USB drive and any testimony regarding its
data. Your Honor.
That's our whole case.
Law School 101, Mr. Baylor, if you steal it or conceal it, you don't get to
reveal it. Not in my court.
And I request that the defendant produce all data stored on the North City
Hospital and our medication dispensers from January 2013 through the present.
Unfortunately, Your Honor, I'm told that that data is erased every 90 days per
company policy.
Okay. After lunch, we'll hear defendant's opening statement.
Court is adjourned.
How can you work for these people?
It's a trial, Rudy. Try not to take it all so personally.
Back for that bourbon?
No, he came to give you something.
Really? Lucky me.
What do you got?
Immunity.
top shelf and i don't want to be paid for it not for her and she didn't
that none of us do
we
love our children in fact when they make mistakes it's our job to love them even
more we hope and pray that they'll
navigate life's problems and not succumb to its temptations, and ultimately that
they'll make good decisions.
But sometimes they don't.
And sometimes those decisions result in the unimaginable.
Like his talented attorney, Donny Ray Black was a young man with a bright
future.
Sadly, however, his story is a tragedy.
Mr. Baylor's story, I suspect, over a long and prosperous career will be a
triumphant one.
But not here.
And not today.
The desire to find a villain when tragedy strikes is a natural part of the
grieving process.
However,
a courtroom is no place for grief.
In here, we deal only with the facts.
Not the emotions.
Not coincidences.
There are no villains here.
There's only a mother who loved her son.
And the heroic doctors and nurses who tried to save him.
Thank you.
That man, he didn't just kill my boy. He killed 14 others.
He's saying a jury's just never going to hear about that.
Let's focus on you and your testimony for now.
Dot, you asked for the secret, right?
It's in the drinks tray.
Ooh, blammo.
If he killed 15 people, that's 15 families who've lost someone. Dot,
the stand next week.
I'm going to wash my hands.
Are you thinking what I'm thinking?
Unlikely.
We should sign him up.
You want more clients?
In case you haven't noticed, this isn't exactly going well.
It's called the Eisenhower principle.
Eisenhower? When you have a problem you can't solve, you make it bigger.
If they won't let Jackie talk about that evidence, will the jury ever know about
the other families?
Rudy, you okay?
We need to sign the other families.
FYI, that was my idea.
If they become our client, then we get access to all of those patient files.
Make it bigger. Dec, you are a power lawyer.
Guess we've got to look for their names.
Does someone want to explain this?
If we sue on behalf of all the other families, then we can establish a
They offered you a deal.
Of course they offered a deal.
Then we have nothing to talk about.
You think I'm wearing a wire?
Really?
I'm your daughter, asshole.
For that reason alone, it's better that you don't know anything.
I would have loved some of that fatherly protection the night you dragged me
into all this.
What do you want from me?
She had a daughter, Dad.
Does that not mean anything to you?
What do you think happened, Jocelyn?
I think you and Prince were supposed to get her out of the country and things
went sideways.
Or Leo changed the plan.
Did you do it, Pop?
I've done a lot of things, but I didn't kill that woman.
I shouldn't have to tell you that.
All right, yes, Mrs. Clancy?
My name is Rudy Baylor. Mr. Alvarez, my name is Dex Shiflim, a legal associate
for J. Lyman Stone. We believe your husband... Your daughter may be a victim
a pattern. A pattern of negligence. and even malfeasance that the hospital
knowingly and willfully covered up. Who told you you can't talk about it?
When did you get this offer? Three weeks ago.
No, you know what? Let me guess. Was it three weeks ago? Mr. Roberts, listen, I
appreciate your time, but do you happen to remember the name of the lawyer that
came to see you?
No, the settlement prevents you from taking part in our lawsuit.
Sorry to have bothered you.
Same story.
Lawyer from Tinley Bridge shows up, check in hand, all for the low, low
keeping their mouths shut. What?
The last guy gave me the name of the lawyer that came to see him.
And?
It was Sarah.
Tinley Britt is the largest law firm in the state. We're representing North City
in a lawsuit right now. It's a pretty run -of -the -mill case.
Hospitals get sued all the time. You know how it is.
And I'm just a first -year associate, so I mostly do witness research. But after
I learned what happened to you, I couldn't help but...
I wonder if you would be interested in exploring your legal options.
I mean, let's face it, Amber.
You're only here because of Jackie.
Hey, what up, everyone?
Today is probably my most important post ever.
One year ago today, I woke my ass up.
I thought I had my tolerance unlocked, but the dope caught up to me.
And I finally got clean.
And this year has been the hardest and the most rewarding journey of my life.
It's black.
When did Donnie Wright post this video?
Three days before he went to the hospital.
I am so proud of him.
I am so proud of him.
Permission to approach, Your Honor.
I'm handing you Plaintiff's Exhibit 3, the report you received from the
hospital.
Yes, that's the letter.
Please read the highlighted portion.
Cause of death, influenza.
Complicated by six men.
And did the report explain what six men is?
It says it's heroin.
But the Google thing says it could also mean morphine.
Do you believe that your son died due to a heroin overdose?
Objection. Your Honor, I'm not asking for an expert opinion.
It's one from a mother who knows her son.
Witness may testify to what she observed.
My son hadn't put that crap in his home for a year and three days.
So how could he die from heroin?
Thank you.
No more questions.
Hey. Well done.
This is Black.
I would first...
I'd like to offer my serious condolences.
I bet you would.
Please, stick to answering the questions, Mrs. Black. Then he should
asking them.
Fair enough.
Mrs. Black, in his long struggle with heroin addiction, how many times did
son tell you that he was clean only to find out later that he wasn't?
Five.
And you just testified.
that your son was clean for a year before he died.
How did you know that?
Isn't it true that you only know because he told you?
Yes, but I don't know. Nothing further.
Hey. Hi.
Brought you a couple suits.
You didn't need to buy me a couple suits. Oh, I didn't buy them.
Guy owed me a favor.
Thought you'd stop by the courtroom sometime.
Oh, well.
Didn't want to rattle you.
Couldn't be much worse.
I heard.
You know, this case...
has always been a fish pretending to be a whale.
The only thing is, I have it.
Norpen's fault. They prove everything, but I can't use them. I already tried to
get them another way.
Sheena raises itself every 90 days.
So do you.
Leo?
Come on, Rudy.
I taught you better than that. He can't lie in court, Bruiser. Why not?
Put Jackie back on the stand.
Judge already said... Is there a better expert on this machine than a nurse who
uses it every day?
Rudy, you've been trying to prove a cover -up that's already happened.
Show the jury that it's still happening.
Leo, that Brad twit, that girlfriend of yours, they're all part of
it. The judge could hold me in contempt.
Throw me in jail?
So what?
I've been in jail before.
We survived.
You know what your problem is?
You still think you're one of them.
You're one of us, babe.
Financials, job history, social media.
I need any and all complaints from patients, whether she treated them
or not.
Where's my Donny Ray team?
I need the AV prep for Leo in one hour. Now we're down to your top five clips.
Team's working hard. I'll have something to you within an hour.
What are you two conspiring about?
Sarah has some thoughts about Jackie Lomanchik.
Is that so?
Nuts and sluts.
She's either crazy so she's imagining things, or she's a slut and can't be
trusted.
Nuts and sluts is a defense for sexual harassment, not bedmail. We need to
discredit her.
Leo, you've already neutralized LeManshik.
You go in after her like this, it could turn the jury against you.
I'm not going after her.
She is.
You're not serious.
Sarah will handle the cross woman to woman.
Better get to it.
She's a junior associate.
I'm on partner track. That's correct, because you are a team player, and I
something more important for you to do.
You're too scared to show his face.
He's busy.
It's all there.
So this is goodbye, then.
We're about to hug.
Mr. Mansha, can you tell us what a NarPens is?
Objection. Mr. Baylor, I am not amused. Your Honor, I'm presenting Mr. Mansha as
an expert witness on the NarPens machine. She's a nurse, not a
702, Your Honor. She used the machine for over 10 years and instructs new
in its use.
I'll designate her an expert on the operation of the machine only. Mr.
have you ever had to access the NarPens data lock?
Many times. Your Honor.
Mr. Baylor, I would be very careful if I were you.
How long does the machine keep its data before it erases it? It never erases it.
Enter into evidence, as plaintiff's exhibit 5, a letter emailed to me this
morning from the Narpen's Corporation.
Will you please read the highlighted portion?
The Narpen's system cannot delete its data without entering the master code,
which is only held by select senior executives at the hospital.
Counsel, approach.
Get ready, you're up soon.
There we go.
Mr. Trott.
It sounds to me like your client has hidden evidence in this case. And worse,
knowingly and willfully destroyed it.
I was told the data was erased.
We have a copy, Your Honor. That evidence has been excluded.
That was before your client started playing games with this court.
Present your evidence, Mr. Baylor.
Ms. Lemanchik, tell us what happened the night Donny Ray died.
When he coded, I ran down the hall.
And that's when I saw Melvin Pritchard leaving the room.
It struck me as odd for two reasons.
One... He's an ER nurse. He didn't belong there. And so?
Well, when a patient codes, it means he's decompensating. So heart attack,
stroke, a catastrophic situation.
We're nurses.
We don't walk out when that happens. We run in.
And why was Donny Ray decompensating? Well, that's the thing. He shouldn't
been. We were treating him, and he was stable.
He just had a bad flu.
Objection calls for speculation.
He's a nurse. She's not speculating. She's diagnosed.
I'll allow it.
It was deemed a drug overdose, which didn't make sense.
So I did some digging, and I found 14 other cases of a patient ODing when
chart said they'd been stabilized.
Melvin Pritchard was the common denominator in every case.
What happened then?
I took my suspicions to the peer review committee, but they deemed it a
coincidence, so I went to Bernie Manfred, the VP of quality assurance.
He must have been grateful that you brought this information to him. He
me.
On the screen is a summary of the data that you took from the Narpen's
What are we looking at?
It's a list of 15 orders of morphine placed by Melvin Pritchard.
Each on the day a patient died of an overdose.
And why is there a cancellation after each one?
That means you've decided not to withdraw the drug.
But when you cancel, you have three seconds until the drawer closes.
Is that enough time to remove the medication?
Yes.
When was the last time you saw him?
When he tied me up in a storage unit.
Melvin kidnapped me to try and get his hands on that list.
No further questions, Your Honor.
Sarah Plankmore for the defendant, Your Honor.
Ms. Lomancek, weren't you in fact fired for stealing data and violating patient
confidentiality? That's what they said. And your suspicions were dismissed by
both a committee of doctors and a hospital vice president overseeing
care. Doesn't that tell us that these accusations are devoid of merit? No.
What it tells us is that they were trying to hide what happened.
You have a history of making wild accusations, don't you? Why did Charlie
break up with you? It's actually relevant.
Your Honor, it goes to the witness's credibility and moral character.
Overruled.
Isn't it true that Charlie broke up with you because you repeatedly accused him
of cheating?
There were other reasons. Did you ever catch him in the act, find any lurid
texts, any photos?
Breakups are hard, aren't they?
So much so that you were stalking him.
You talked to Amber.
And I spoke to the Charleston police.
I have here three complaints by Charlie and his new wife that you were stalking
and harassing him both in person and through repeated texts and calls.
Now, Amber made that complaint, okay? Not Charlie. Never Charlie.
Wasn't it you who cheated first?
We were taking a break at the time. Did your rage about your personal life
impede your judgment at work? No. You called in sick for a week after that
break, right? No, I take my work very seriously. Oh, I'm sure you do. Where
you get your nursing degree?
Charleston Southern University.
And they let you graduate even though you cheated on a final.
That was a mistake.
When you were caught, you lied about it and only came clean when a classmate
confessed to the plan.
We had pulled two all -nighters in a row at the hospital. We hadn't slept in
days.
We just decided to help each other out.
It was a mistake. I never did anything like that again. Except for when you
cheated on Charlie. Miss Lomantic, it seems you have a problem with honesty.
Objection argumentative. Withdrawn. I'm done.
Going away, are we?
We do what we gotta do.
I guess that means he's going too.
You say bye to Rudy?
Then why would I do that?
Oh, come on. Don't bullshit me.
You made me hire him, remember?
You gave him shifts when he was short on cash.
You even gave him a gun when he needed one.
Is that what he told you?
He didn't have to.
What are you doing here, Bruce?
That kid.
cares about you.
And he is fighting for his life in that courtroom and he's going to lose.
And why?
Because when Leo called, you slithered back on your belly.
If you had just turned Melvin in, Rudy could have won this thing by now. And
trust me, those assholes need a beating.
I hope you and Lyman have a nice life together.
I haven't seen an associate destroy a witness like that since I did it myself
years ago. Well, thank you for trusting me, Leo. Well, get prepared for a lot
more. I'm promoting you to second chair.
Are you serious?
Leo, she's never worked a trial. She hasn't been no basic procedure.
But she doesn't know I'll teach her. What she did today, you can't teach.
Meet me for breakfast tomorrow. Emily will give you the detail. I'll be there.
Thank you for that. Does this mean I'm off the case? You can sit third or pivot
to Greenwald. It's up to you.
Why are you doing this?
I'm not doing anything.
I didn't do it for you in the beginning. There's nothing different.
Yes, it is.
You don't want to sideline me like this.
I don't. I know where the bodies are buried, remember?
What bodies? Jane and Ethan, Pritchard, Lomanchik.
Everything you've done to win this case. Everything I've done.
But you hired Jane.
You told her what to do. You paid her. Yeah, on your orders.
I don't remember any of that.
You paid Prince and Lyman to leave the country.
Did you already forget that, too?
Thank you, Miss Heller.
What the hell is she doing here?
I didn't pay Prince and Lyman.
That was you.
Remember?
You son of a bitch.
I'll take that as a no unfitting third.
Relax, Brad. You're still useful.
As a backup singer.
But that girl's a star.
You deserve a better lawyer.
I think so, huh?
You know what I've seen in here?
I've seen someone telling the truth.
Truth is not your client, Leo F. Drummond.
You're not him, thank heaven.
You should invite your mom down here.
Let her see a boy do his thing.
Win or lose, she'll be so proud.
After we picked her up from your place, we took turns driving to the Canadian
border.
Rosalie was scared.
She'd been having second thoughts the whole way up there.
We should have told her up front there'd be a handoff. We spoke to her.
Hey, kid, it's me.
Listen, I need you to come down to the bar.
I got something for you.
It's important.
They were chasing her through the woods.
Not to hurt her.
Pray?
Pray?
He's downstairs.
What are you worried about?
Come on.
Go on.
You think it doesn't bother me?
every day.
I want you to tell them.
Do whatever you need to do to get yourself out of this.
Understand?
Your Honor, as a rebuttal witness, we call Melvin Pritchard to the stand.
It's not too late. You can still walk away.
If you have a question you want to ask, ask it.
Buddy, you're a fighter. You never surrender. It's what got us this far,
can also think up.
Have you reached a verdict?
Yes, Your Honor, we have.
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