"♪" "CARY:" "And does this abandoned pool belong to one of your foreclosed properties?" "MAN:" "It belongs to one of the properties where the householder could not repay his loan." "And therefore, we exercised our prerogative as the bank holding the lease to foreclose." "And this pool at 233 Graham Court..." "WOMAN:" "Can I interrupt here?" "It would save us all a lot of time to just stipulate that the five swimming pools are part of the foreclosure package exercised by the Atlantic Commerce Bank." "Good." "If you stipulate to that, it will save us time." "I'll be right back." "You okay, Kaley?" "Yeah." "Thank you, Mr. Gardner." "How's it going?" "Pulling teeth." "What's that?" "Notice of mediation." "For?" "Both of us." "Wednesday." "Why?" "The bankruptcy." "We have another five weeks." " I know." " We need 60 million by February." "And yet, one of our creditors wants a mediation on our progress." " Which one?" " I don't know." "Check with Clarke." "If we're being called on the carpet, he is, too." "Hmm." "Wouldn't hurt to go in with the 15 million from Atlantic Commerce." "We went down to 13." "It would be nice to keep that settlement above ten." "I'm doing my best." "Counsel, please tell your client to stop evading and answer." "WOMAN:" "Yes, after you rephrase." "Very simply, sir, you foreclosed on these..." " The homeowners neglected to pay." " You left these homes abandoned, you left these pools..." " We did nothing." "These pools?" " No, sir." "After you kicked the homeowners out, you did nothing with the swimming pools." "You let the water stagnate." " The water was stagnant already." " And that water drew mosquitoes." "These mosquitoes, to be exact." "And those mosquitoes carried West Nile virus to my client," " Kaley Spence." " WOMAN:" "Oh, come on." "Palsgraf v. Long Island Railroad." "There is no way that Mr. Millam and his bank could know of this proximate cause." "WILL:" "Good, then let your client testify to that." "Because what I have here is a warning from the CDC mentioning your pools as the culprit." " We were not aware of that." " "We"?" "Are we speaking for the whole bank here?" " I was not aware of that." " Well, were you aware of this letter of complaint written by the neighbors, including Mrs. Spence, about the declining conditions of the foreclosed homes, including the pools?" "No." "I was not aware of it." "You can see" " it was not addressed to me." " Yes." "It was addressed to your bank president, Wilkes Ingersol." "Luckily, that's who we're deposing next." "♪ I love mountains, I love rolling hills ♪" "♪ I love the flowers, I love the daffodils ♪" "♪ I love the fireside when the lights are low ♪" "♪ Boom-dee-a-da, boom-dee-a-da, boom-dee-a-da, boom... ♪" "WILL:" "It's up to you now, Alicia." "They sent it up the line to the bank president." "I'm supposed to depose him in ten minutes." "How's Minnesota?" "Quiet." "WILL:" "Ask the president if he ever saw the letter from the homeowners." "If he lies, we got them." "They don't know we have the notes from the bank's quarterly meeting." "Get his backtracking on record, and we win." "Okay." "I'll call you back in a few hours." "♪ I love the ocean..." "Wow, look who's here." "Everywhere I turn." "Alicia." "What a pleasant surprise." "How's bankruptcy going?" "That which doesn't kill us makes us stronger." "Yeah, well, then you're gonna be pretty strong." "So, where are we?" "Uh, the business center." "They got a business center here?" "For the record, I want to restate our agreement." "Mr. Ingersol's a busy man, and he can only offer you three hours for your deposition." "After that, he has to get back to his ranch." "For his vacation?" "His working vacation." "Chopping wood?" "Milking cows?" "It's hard work." "So, we're in agreement, Mrs. Florrick, about three hours?" "If it's a true three hours, yes." "And if you're in agreement to have the judge on call so that she can immediately settle any and all objections." "Yes, of course." "Are you getting cell phone coverage here?" "If I stand on my bed and put my arms over my head." "Okay, we're ready." "So, the clock will start as soon as he walks through that door." "As soon as he sits in that chair." "Oh, let's not quibble." "Good." "Then the chair." "MAN:" "Wilkes Ingersol." "I'm the president of the Atlantic Commerce Bank, and a trustee of the Mercantile Exchange." "Well, it's nice to finally meet you, Mr. Ingersol." "You're a hard man to find." "Really?" "Well... that's not what my accountant says." "(laughter)" "We've been trying to depose you for 14 months now." "CANNING:" "Mrs. Florrick, if you wanted to read that into the record, you could have done so before Mr. Ingersol arrived." "INGERSOL:" "It's all right, Louis." "My apologies, ma'am." "I don't mean to be flippant." "Thank you for arranging this deposition near my ranch." "I hope you weren't inconvenienced." "I'm fine." "Now, sir, if we could turn to these foreclosed homes and their swimming pools..." " Yes." "Um, could I say something first?" " Certainly, sir." "I understand there are a lot of homeowners who are underwater." "I understand many homebuyers were enticed into taking on adjustable mortgages that eventually bankrupt them." "But what I often think is that banks are made the bad guys in these equations, and that is unwarranted." " Thank you, sir." " But what I wholly condemn are any efforts to advance political causes through legal means." "I mean, for example, uh, communities using eminent domain to address bank foreclosures." "Or here, using this painful circumstance of a young child with West Nile virus to force us to change our methods on foreclosures." "I think you've been misinformed, Mr. Ingersol." "Kaley Spence is suing you for $15 million." "13 million." "She's suing you because she had a promising career as a ballet dancer, and now she needs full-time care." " We don't need the photos." " I think we do." "INGERSOL:" "Please leave them." "She's a lovely girl." "I have a 15-year-old daughter myself." "ALICIA:" "Sir, did you see this letter, written by the residents of the community complaining about the state of these foreclosed homes?" "CANNING:" "Objection." "We have no foundation" " for this letter." "ALICIA:" " Mr. Canning, this is a deposition." "There's no need for foundation." "That's not true, Mrs. Florrick, and I won't have" "Mr. Ingersol sandbagged..." "Then let's call the judge." "She made you sit down for this deposition." "She will make you address my question." "I'm sorry, Mrs. Florrick." "We're gonna have to leave it there." "No." "Wha... wait a minute." "INGERSOL:" "I just received an emergency text I have to address." "Sir, you have barely been here for three minutes." "I have only asked you one question." " Two." " No, one." "The judge was explicit in her ruling." "If we made the effort to be near your ranch, you must sit down with us" " for at least three hours." " And I will." " But, a in, this is an emergency." " No, sir!" "I'll be back this afternoon at 2:00." "Please be patient." "You will get your time." "I promise you." "Well, that is unfortunate." "FRANK:" "No, I think you're doing well." "We expected a bump in Maddie's polling." "She's the fresh new thing." "Yes, we expected that, too." "We're still beating her 47 to 42.5." "That's outside the margin of error." "I know." "We're not worried." "And yet you're here." "It's a visit." "The Democratic Committee has a lot invested in your boy Florrick." "We want to make sure he wins." "And you're worried he won't?" "I'm worried the sun won't rise tomorrow, Eli." "It's a visit." "That's all." "Thank you." "Come again sometime." "I heard something." "Something that worried me." "I heard your offices were raided." "It's nothing, Frank." "It's not nothing." "No raid is nothing." "A raid is something." " It's not about the candidate." " I know it's not about the candidate." "It's about you." "(closing door):" "I'm not hiding anything from you." "There are forces within the Justice Department that do not want Peter to win the governorship." "Now, they don't have the facts to come after him, so they're coming after me as a steppingstone to Peter." "And they have the facts to come after you?" "N... no." "I'm just saying, they know that Peter without me would be limping." "So, they want this." "They want you coming to me suggesting..." "What are you suggesting?" "Not that you resign." "You're not an issue yet." "But you need a strong second in case you do become an issue." " I know you don't like it, Eli." " (laughs quietly)" "But you need a second." "♪" "So, 2:00 p.m., huh?" "Yes." "I'm not sure what happened." "The judge won't be happy." "Mr. Ingersol is a very..." "If I hear one more time how busy Mr. Ingersol is," "I will strangle you." "(phone rings)" "Hello?" "Yeah, yeah." "I understand." "No, uh, she's here." "I'll tell her." "Okay, thank you." "Bye." "Mr. Ingersol would like to apologize..." " Let's get the judge on the line." " It's an emergency." "He said he just has to delay until tomorrow morning." "He set aside three hours starting at 10:00." "He won't count today's ten minutes against it." "He wanted me to apologize to you personally." "He said he really enjoyed his time with you this morning." "Let the record reflect that Mr. Ingersol has refused to attend..." " He didn't refuse to attend." " .. failed to appear in a court-mandated deposition, despite promising to attend between the hours of 2:00 and 5:00 p.m. today." "Alicia, you might want to look at this tonight." "The CDC has revised their report." "It seems there's another possible cause for the outbreak of West Nile virus besides just our swimming pools." "WILL:" "A koi pond?" "!" "ALICIA:" "Yes, from a house that wasn't foreclosed." "Damn it." "The CDC report isn't saying it's definitely from the koi pond or from the swimming pools." "But the koi pond also had stagnant water." "The bank just got its wiggle room." " Yup." " Okay, Alicia, we'll handle this on our end." "You just get the bank president on record about the neighbors' letter." "When is he supposed to arrive?" "10:00 a.m. tomorrow, but I think I'm getting the runaround." "Yeah." "They'll probably wait until you're out get breakfast or something, then they'll tell the judge the witness was available, but they couldn't find you." "Mm." "Unfortunately, you'll have to outwait them." "Stay close to your room so they can't say you were out." "Oh." "Yeah, okay." "But I was only planning to stay for one night." "We'll get clothes and incidentals out to you." "Mr. Hayden." "Hello." "I've been trying to get to you all day." "Yes." "I've been in meetings" "Do you have a minute?" "No, actually, I don't." "Have you, uh, received a notice of mediation?" "No." "But you..." "Mr. Hayden, is... is there something I should know?" "(elevator bell dings)" "(door opens, Clarke sighs)" "I requested the mediation." "You?" "Why?" "You need to be removed from your positions." "The firm can't be merged with you in control." "Mr. Hayden, this is... we've been nothing but cordial." "This is not about cordial." "I had a firm ready to merge, to pay off your creditors, and you sabotaged it." "It was a bad deal." "They wanted to break us up." "Yes, they did." "That's exactly the point, Ms. Lockhart." "You have creditors, you owe them money." "They are not interested in your self-fulfillment." "They are interested in their money." "Then let us make them their money." "Well, you'll have a chance to argue that in mediation." "(elevator bell dings, buzzing)" "If we merge the firm, the creditors will receive 70 cents on the dollar right now." "Or they can trust that you will bring this firm back." "Either way, I'll see you in mediation." "Oh!" "Oh!" " No, no, take it." " No, no." " I'm fine." " You." "I probably have more in my room." "Are you sure?" "I can split it with you." "No, that'd be messy." "Thanks." "I think the next store is 50 miles away." " Are you here for the air show?" " No." " There's an air show?" " Yeah, I think so." "The hotel clerk kept talking about it." "It was..." "Oh." "Excuse me." "I have to run." "Mr. Canning!" "Hi." "I'm here." "I'm here." "What's up?" "Oh, yeah, Alicia, I was..." "I was just about to leave you a note." "Mr. Ingersol can come in earlier this morning." "Right now, as a matter of fact." "Uh, we thought we'd missed you." "I'm ready." "I will meet you at the business center." "Right." "(clock ticking)" "Must have been delayed." "That seems to happen a lot." "I have a friend who... who's dying." "Wants me to give the eulogy at... at his funeral." "He just e-mailed me." "He's dying, and he sent you an e-mail?" "His wife did." "I hate that people my age are starting to die." "It's really horrible." "It is." "He was my roommate in college." "Ian Keyes." "Smartest guy I ever met." "Ever give a eulogy?" "Yes." "To someone close?" "Yes." "Who?" "My father." "I'm sorry." "How old was he when he died?" "60." "That's young." "It is." "(clock ticking)" "Am I upsetting you?" "No." "Um, why don't you call Mr. Ingersol, and see what time he's gonna be here?" "I'm not playing you, Alicia." "He's coming." "I know." "Yeah." "We're here." "No?" "Okay, wh... when?" "All right, well, just keep me in touch." "2:00 this afternoon." "Let the record reflect that Mr. Ingersol has refused to appear at a court-mandated deposition... again." "DIANE:" "You sure you want to do this?" "What's the downside?" "You're a low priority." "Provoking them with a harassment suit could make you a high priority." "I don't think I have any option." "WENDY:" "I'm sorry to keep you waiting." "I'm brand-new on this case, and there was a disagreement about who should take this meeting." "Ms. Lockhart, Mr. Gold, good to see you again." "Oh, come on!" "This is a conflict of interest." "What's that, Mr. Gold?" "You ran against my boss." "You lost." " I beat you." " Yes, that's true." "Two years ago." "You asked for a proffer against Mr. Florrick." "That is a conflict of interest." "No, that was my investigator," "Mr. LaGuardia." "I have since rescinded that offer." "Discounts for donations is a serious business, Mr. Gold." "The DOJ takes it very seriously." "God." "No one disappears." "They all come back, like zombies." "Eli." "This is a complaint, Ms. Scott-Carr, against the DOJ and your department." "We are charging you with harassment." " Please read it." " I will." "And I'll have my secretary contact you about a time to interview." "ELI:" "You want to beat Peter, do it at the ballot box." "Don't use this petty ploy." "This is not about beating Peter." "So you're angry at me now?" "(laughs)" "Do I look angry?" "My directive here is simple:" "clean up political corruption." "That's all." "You underestimate me if you think I'm working from bias." "I'll be in touch." "And you'll read our complaint?" "Oh, yes." "I have it right here." "Sorry, I have to get to my next meeting." "ALICIA:" "Hello?" "Oh, hi." "I just saw you had to run off, so, I..." "Oh, my gosh." "You didn't have to do that." "I know." "It was nothing." "Well, thank you." "Uh... what do I owe you?" " No, no, no, nothing." " Well, I have to pay you something." "No, you don't." "No." "Next time." "I'm Simone." "Oh, um, Alicia." " There aren't many people around here." " Yes, I know." "It's so strange that they built this big hotel up here." "So, are you here for vacation or something?" " Oh, no." "Work." "You?" " Uh." "Oh, my husband's here for work." "You are probably the lawyer that he's here to meet." "Are you Mrs. Canning?" "Yes." "Are you Mrs. Florrick?" " Yes." " My husband speaks so highly of you." " He does?" " Yes." "He does." "He thinks you're fantastic." "For a while there, I thought I should be jealous." "(laughs) I'm joking." "But we should have breakfast sometime." "You know, if we're going to be here for a while." "Are we going to be here for a while?" "I don't know." "You tell me." "(laughs) (laughs)" "Well, it was really nice to meet you." "So, I'll call you for breakfast?" " Good." "Yeah." " Okay." "Simone?" "Yes?" "I was so sorry to hear about your husband's friend." "The one who's dying?" "Who's that?" "Oh, never mind." "It was my mistake." "It was lovely to meet you, Simone." "You, as well, Alicia." "Good job, Kalinda." "He's sure?" "Yeah." "Look, as far as I can tell, the Aedus..." "Eedus...?" "Aed...?" "Aedes albopictus." "The... this kind of mosquito breed doesn't transmit West Nile, so it couldn't have come from the koi pond." "That virus is transmitted by the ae-aed..." " The other one?" " Aedes aegypti." "Aedes aegypti." "By a different type of mosquito." "Excellent." "Very good." "Just get him on the record." "Ah, that'll be fun." "We'll call you back, Kalinda." "What's going on out there?" "He's getting Cary in line to testify against us." "I just want to make sure we're on the same page." "I think we are." "Yeah." "Good." "Thank you, Cary." "Cary?" "Yes?" "What was Clarke discussing with you?" "Uh, nothing." "He just wanted to know about the clients who left last week." "And what did you say?" "I said nothing." "I just listened." "We're just a little worried he's trying to line up a case against us, Cary." "And that he might use you." "Do you think that's a possibility?" "He didn't say anything about that." "Can we, um, talk to you, Cary, about possibly testifying for us?" "(crows cawing) 2:30." "And here we are again." "Why don't you go for a walk?" "I'll get you when he comes." "(laughs)" "How's your friend who's dying?" "Have you heard any more from him?" "No." "Why?" "Maybe you should call him." "Maybe he's dead." "Excuse me?" "Oh, I'm sorry." "Am I being insensitive?" "How's the eulogy coming?" "I mean, maybe you could ask Simone to help you on that." "You met my wife." "Yes, I did." "She's wonderful." "Yes, she's... my better half." "She's your only half." "Funny, she'd never heard of Ian Keyes, your roommate." "Yeah, well..." "I don't share everything with her." "Your lies, for example." "You don't share your lies?" "No." "Those I save for you." "(laughs)" "What was even the point of lying about a dying friend?" "I don't know." "It was a way of connecting." "Didn't you feel we were connected?" "How does a bastard like you end up with such a wonderful wife?" "Women like bastards." "Didn't you notice that?" "It's like a challenge." "Beauty and the Beast." "It fits in with all the fairy tales you grew up consuming." "(laughing):" "Oh, my God." "(phone ringing) Oh, there's Godot." "Hello." "All right." "Really?" "Let the record show that Mr. Ingersol has refused to attend a court-mandated deposition for the fourth time." "He was literally" " a minute away when he had another call." " Oh, really?" "Just a minute away?" "Wow." "He says he can reschedule for tomorrow at 10:00." "Okay, sure." "Um, it'll just... it'll give you some time to read this." "It's saying that the CDC is updating their report again." "The mosquito carrying the West Nile virus could not have come from the koi pond." "That's the wrong kind of mosquito." "The right kind of mosquito could only have come from the swimming pools." "So, nice try, Mr. Canning, but you lost." "And every day that this deposition is delayed, the judge is getting angrier, so... (clicks tongue) might want to rethink your strategy." "(dialing touch tones)" "Yeah, it's me." "Yeah, I need you to look into something." "So, Kaley, hi." "Hi." "I just want to ask you a few questions, and I know they might seem odd to you, but please bear with me." "Have you ever heard of Aedes aegypti?" "No." "Well, I can understand why." "That's a very long word for a very small mosquito." "You don't have to patronize her." "She's not eight years old." "Thank you, Mr. Agos." "This is an Aedes aegypti, Kaley." "This is the breed of mosquito that carries the West Nile virus." "We didn't know that until your attorneys pointed it out, so thank you, Mr. Gardner," "Mr. Agos." "What do you have?" "Now here are diagrams of the five abandoned swimming pools that bred the mosquitoes." "WILL:" "Seems you've dropped the "supposedly"." "Are we in agreement, the pools bred these mosquitoes?" " Yes, we are." " Hallelujah." "Now, here are five diagrams of the five backyards, and do you see here?" "Here are the distances between the pools and the perimeter fences." "30 yards, 40 yards." "And so on." "Do you see?" "Yes." "The thing about Aedes aegypti:" "they are peridomestic mosquitoes." "That means they exhibit short flight ranges of less than 50 feet." "That means there is no way they could have flown beyond their respective yards." "Are you testifying here, Martha?" "All preamble." "Here's my question." "Kaley, did you climb the fence into one of these abandoned yards?" "Sorry to ask you again, Kaley, but you must tell the truth here." "Did you climb the fence into one or more of the yards of these abandoned houses?" "(sniffles)" "One." "With my friends." "Then, I'm sorry, but the plaintiff trespassed onto our property, and we cannot be held liable for that trespass." "This suit is over." "My name is Serafina Norvey, and before we get started," "I'd like to set the ground rules for this mediation." "Granted, we're in your offices, and outside those doors, you may all be bosses, but in here, I am the empress." "Now, I understand, as the court-appointed trustee, you'd like to have the two principals removed as managing partners?" "CLARKE:" "Yes." "They blocked a merger of the firm that I'd arranged with Burl Preston." "That merger would have met all the financial obligations" " of the bankruptcy." " Is that true?" "A merger was never part of the original arrangement." "Mr. Hayden overstepped his authority when he tried to arrange that deal before the full term of the five-month deadline." "My job was to satisfy the terms set down by the court." "Actually, it was against the terms of the court, in that it did not honor the original timeframe." "Also, it worked to undermine our progress." "What progress?" "We've managed to raise a great deal of money in a short amount of time." "How much?" "Excuse me?" "How much money?" "$20 million." "Which is 40 million short of what they need." "WILL:" "And we are very close to finalizing a $13 million settlement with Atlantic Commerce Bank." "They are not "very close."" "They are in deposition." "Which is how it works, Mr. Hayden." "You negotiate in depositions." "You try to stay out of court." "Ma'am, if we had a trustee who understood the law..." "Excuse me." "I know as much as anyone...!" "All right, all right." "This is not marriage court." "I'm not here to make you like each other." "But, Ms. Lockhart," "Mr. Gardner, I think you're losing sight of the big picture here." "This isn't about you." "This is about your creditors." " Yes, Your Honor." " "Ma'am."" "I'm not a judge." "Excuse me, ma'am." "Our creditors are voting with their pocketbook by buying up our debt." " They are?" " WILL:" "Yes." "We recently got in touch with our creditors about this mediation, and they informed us that they no longer are our creditors." "A consortium of financiers called Encinal Equity has purchased their debt." "And people don't buy bad debt." "Yes, but by that logic, your creditors are fleeing your debt by selling it." "People don't sell good debt." "DIANE:" "Ma'am, all we ask is for enough time to present our arguments." "This mediation has come as quite a surprise to us." "How long will you need?" "We should be prepared to present witnesses and evidence by next week." "Tomorrow." "CARY:" "Let's talk about the swimming pool at 233 Graham Court." "This one here." "This pool had several water features, correct?" "I'm not sure what you mean." "In addition to having a deep end and a shallow end, there was also a diving board, a waterfall, and a grotto?" "Okay." "I agree." "Was the grotto boarded up after the bank took possession?" "No." "Did you receive reports from neighbors that the waterfall feature was being used by skateboarders?" "Where's this going, gentlemen?" "Mr. Millam, would you admit the pool was an attractive nuisance?" "Objection." "That does not apply here." "Kaley climbed a fence to reach the pool." "Which makes it a textbook case of attractive nuisance." "It's the responsibility of the homeowner... in this case, Atlantic Commerce Bank... to secure the swimming pool and make sure it did not become a danger to children." "Once again, there was a fence, and your client is not a child." "WILL:" "Kaley Spence was 12 years old at the time." "A very young, sheltered 12." "So you were sheltered?" "Is that it, Kaley?" "You want to question our client, depose her." "Oh, you sure are well-dressed." "Thanks." "And you are in my office." "FRANK:" "Oh, I see you two have met." "Eli Gold, Jordan Karahalios." "Oh!" "The boy wonder." "(chuckles):" "God, I hate that name." "The ever-quotable Rahm Emanuel." "Never gonna live that down." "We were headed out to see Peter." "I figured you two should meet first." "Because...?" "FRANK:" "That thing we discussed before, about how you needed a second." "I like Peter." "He's not one of those processed sales jobs." "He's got grit." "Jordan wants to offer you guys some time." "He's had lots of offers." "Even Maddie Hayward, isn't that right?" "Yeah, she's great." "A little green, maybe." "So, you think you two can work together?" "I heard you like to work alone, Jordan." "I do." "But I also like to learn from my elders." "I just want to get an idea how you might handle certain situations, okay?" "Okay." "Would you ever go into a store and take something without paying for it?" "KALEY:" "No." "MARTHA:" "If you got lost in an airport, what would you do?" "Find a policeman and ask him to help." "Were you ever allowed to stay home alone without a babysitter?" "Sometimes." "Well, I used to." "Not now, because of what happened to me." "Thank you, Kaley." "That's all." "Your client is mature enough to understand right and wrong." "Attractive nuisance does not apply here." "That's not for you to decide." "That's right." "It's for a jury." "Which means court." "Which means we're not negotiating a settlement." "Damn it." "Still in a holding pattern." "He's supposed to be here in an hour, but I'm not holding my breath." "We really need Ingersol." "The case is going down the drain." "I think it's about this merger" " with Corsica Pacific." " What do you mean?" "Alicia, they're stalling because they don't want a $13 million settlement" " to mess up this merger." " Well, we can't wait." "Alicia, is there any way you can get proof they're stalling?" "Bad news, unfortunately." "Really?" "What a surprise." "Yeah, it'll have to be pushed till this afternoon." "Something came up at the last minute." "I say, it's pushed till this afternoon." "I thought we would use this time to depose someone else." " What, for practice?" " Rita!" "What's going on here, Alicia?" "Please have a seat, Ms. Neves." "Would you state your name and your occupation for the record?" "Rita Neves." "I am a housekeeper here at the Janesville Mountain Retreat." "What, are we playing games here?" "And this morning, were you near enough to Mr. Canning to overhear his telephone conversation?" "RITA:" "Yes." "I was in his room cleaning while he was talking on the phone." "Objection." "That's hearsay." "Can you describe what you heard?" "He say, "No, don't come now." "I call when Florrick steps out."" "Objection." "That had nothing to do with Wilkes Ingersol." "Is that statement for the record?" "This conversation is totally taken out of context." "It had nothing to do with Wilkes Ingersol." "It was to my... partners in Chicago." "Ed, you can come in now!" "What now, Mrs. Florrick?" "You got some farmers you want to depose?" "Can you state your name and occupation?" "Ed Jeffries." "I work at the front desk." "And, um, can you tell me how many calls were made from Mr. Canning's hotel room?" "Objection." "Your objection has been preserved for the record." "Please tell me how many calls were placed from Mr. Canning's room?" " Four." " That is private information." "And were all those calls placed to the same number?" "Three to the Ingersol Ranch, one to another local number." "So no calls were placed to Mr. Canning's partners in Chicago?" "Well, there were no calls to Chicago." "Thank you, Ed." "Oh." "Don't you want to stay for my call to the judge?" "Or do you want to be held in contempt in absentia?" "(dialing)" "JUDGE:" "Given this evidence, Mr. Canning," "I rule for the plaintiff." "Present the witness or be held in contempt." "When is the earliest he can be deposed?" "Tomorrow morning at 10:00." "Your Honor, Mr. Canning has been saying that for two days now." "Mr. Ingersol is dealing with an ongoing emergency." "Mr. Canning, have your client there at 10:00 a.m. or be held in contempt." "Do you understand?" "I do." "(line clicks)" "I'll see you at 10:00." "I don't need a lawyer." "Yes, but you never know about the future, Mr. Ellstrom." "Tobin." "I'm not in politics anymore, Ms. Lockhart." "The Department of Justice is making moves against past and current campaign managers, so I think that you should review your past campaigns." ""Making moves"?" "On what issue?" "Discounts for donations." "Campaign managers offering discounted legal services in exchange for campaign contributions." "That's just Chicago politics." "And since you were a lawyer prior to your work as Wendy Scott-Carr's campaign strategist," "I thought there might be some issue there." "This is about Wendy Scott-Carr?" "No." "It's about all your campaign work." "But Wendy Scott-Carr especially?" "Okay." "I'll think about it." "Certainly." "Here's my card." "Don't forget." "(cell phone ringtone playing)" "Hello, Tobin." "How nice to hear from you." "TOBIN:" "Do you know a lawyer named Diane Lockhart?" "Yes, I do." "Why?" "She just approached me about my past work with you." "She did?" "Yeah, she said the Department of Justice is investigating discounts for donations, and that I might be implicated." "(sighs)" "She wanted you to call me." "What?" "She wanted you to call me so I would know that if I pursue them on discounts for donations, they'll pull you in." "No, she just wanted me to hire her." "No, Tobin, she didn't." "This was a warning shot across my bow." "So what are you gonna do?" "We ran a clean campaign, Tobin, didn't we?" "Well, yes, but nothing's 100%." "No, we ran a clean campaign." "Just don't talk to her again." "(knocking)" "Kalinda." "And clothes." "And incidentals." "Ah." "(sighs):" "God, it's quiet." "Yeah." "You've had two days of this?" "And two nights." "It's not that bad, actually." "(sighs)" "Really?" "I'd kill someone." "You know what I miss about my old life?" "Before the glamour of the law?" "What?" "The quiet." "At home, in the afternoons," "I would drink every day at 3:00." "A glass of red wine." "Waiting for the kids to come home." "I miss the silence in the house at 3:00." "Just... nothing going on." "I miss this." "Yeah." "(chuckles softly)" "I'm sorry." "I know." "(chuckles softly)" "You know, I don't think Ingersol's gonna show up tomorrow at 10:00." "I know." "Cary thinks that they're trying to avoid a road bump in their merger." "Do you have that other number Canning was calling?" "There were three to the ranch and one to a local number." "Yeah." "What's your thinking?" "(sighs):" "I don't know." "Maybe there's a real emergency." "Cary Agos." "A fourth-year associate at Lockhart/Gardner." "DIANE:" "And were you asked by Mr. Hayden for your assistance" " over the last three months?" " Yes." "And for how many hours a week were you asked to help him?" "Roughly... ten hours a week." "And this was done on your time?" "CARY:" "As a fourth-year associate, very few hours in a day actually constitute my time." "But you managed?" "Yes." "Yes, I did manage." "DIANE:" "And what did Mr. Hayden ask of you?" "He asked me to be his tutor." "DIANE:" "His tutor?" "Yes." "He asked me to help him study for the upcoming bar exam." "DIANE:" "And what prompted that arrangement?" "Mr. Hayden had attended law school years earlier, but never attempted to pass the bar." "Now working at Lockhart/Gardner had reinvigorated him." "DIANE:" "And did you feel you had any choice in the matter but to help him?" "No." "Thank you, Mr. Agos." "Anything, Mr. Hayden?" "Uh, yes." "Uh, you stated that fourth-year associates rarely have time of their own." "Yes." "But you found the time to help me?" "I didn't feel as if I had a choice." "You held sway over the entire firm." "Isn't it true that I offered to pay you for your assistance?" "Yes, you did." " And did you refuse my offer?" " Yes." "Did I ever state or imply that you would be afforded preferential treatment for your help?" " No, you did not." " Did I ever state or imply that you would be penalized if you refused to help me?" "No, you did not." " Your Honor..." " "Ma'am."" "Ma'am." "Lockhart/Gardner... has no shame in trying to besmirch my name for their own personal gain." "It goes to their... illogical passion for winning at all costs." "Once again, I ask that Diane Lockhart and Will Gardner be removed from their managerial positions at the firm." "I'll take your words under advisement, Mr. Hayden." "Ingersol's not dodging the depositions because of the merger." "WILL:" "Why then?" "He's been seeking treatment at an experimental cancer center." "He's... since when?" "A few months ago." "The number Canning dialed from here was a center run by Vivek Assadullah, a cancer specialist." "Ingersol's battling non-Hodgkin lymphoma." "That's not public knowledge." "No, it's not." "Thanks, Kalinda." "Is Alicia there?" "Sure." "Alicia." "Yeah?" "Use it." "They don't want it to come out before the merger." "I know." "I'm on it." "(indistinct chattering)" "What the hell?" "Oh, no." "Ms. Scott-Carr, do you have an appointment?" "No." "We're here to confiscate Eli Gold's files." "He operated his crisis management firm out of these offices, which makes Lockhart/Gardner open to investigation as well." "That is bizarrely tenuous." "And yet, supported by the judge." "Thank you... for the warning shot." "It gave me time to acquire the warrant." "This investigation is so hypocritical." "Okay, the files in here first." "(clock ticking)" "Don't worry." "He's coming." "He's just... a few minutes late." "(car approaching)" "O ye of little faith." "(car doors shut)" "ALICIA:" "Good afternoon, Mr. Ingersol," " and welcome back." " Thank you." "How are you feeling today?" "Good." "Why?" "Just a pleasantry." "Well... thank you." "I'm good. (chuckles)" "Good." "Why don't we pick up where we left off." "Did you see this letter that was written by the residents of the community, complaining about the state of the five foreclosed homes and their swimming pools?" "I, uh, did not." "You see it's addressed to you?" "I do." "If I read every letter addressed to me," "I wouldn't have time to... shave or sleep." "(chuckling)" "So that answers that, Alicia." "Any other questions?" "Mr. Ingersol, are you aware that it is an SEC violation to withhold an illness from shareholders?" "Objection." "Relevance." "Your objection has been noted." "Are you aware that it is an SEC violation?" "Yes, but I'm not sure what this has to do with your lawsuit." "It has to do with your intent to delay, Mr. Ingersol." "Atlantic Commerce is a publicly held company." "The shareholders have a right to know if the leader is facing a critical illness." "And according to his profile," "Dr. Vivek Assadullah is a specialist who conducts experimental treatments" " for non-Hodgkin lymphoma." " CANNING:" "Objection." " This is beneath you, Alicia." " No, unfortunately, it's not." "The emergency you were dealing with, Mr. Ingersol, was... uh, Ms. Court Reporter, do you mind stepping out for a moment, please?" "My name is Mika." "So sorry." "Mika." "Of course." "(door opens) You were being treated for non-Hodgkin lymphoma, and you didn't want this knowledge made public before your merger with Corsica Pacific." "This does not have to go on the record, Mr. Ingersol." "We have been trying for weeks now to negotiate with Mr. Canning." "And if you approve this settlement of $15 million, the questioning can end right here." "(door opens)" "DIANE:" "Uh, one second, Eli." "(quietly):" "Alicia?" "Yes. $12 million." "$3 million to us." "Uh, good." "I'll be right there." "Yeah." "As I was saying, Eli, unfortunately, this changes everything." "Wendy's doing this so you can't be my lawyer." "I know." "But now that we're part of this... probe into your practices, we are precluded from representing you." "We have a list of potential attorneys." "I've called the top three." " All are ready for your call." " And so it goes, the endless cycle of Chicago investigations." "JORDAN:" "Hey, guys." "Do you know when the old man is coming back?" "Eli." "There you are." "Let's talk about debate prep." " Let's" " Maddie Hayward is putting all her time into prep." "That's when she really wants to make her mark." "And I looked at the schedule, and you... you barely have Peter down." "WILL:" "We received a settlement offer today for $12 million." "DIANE:" "And just today, Encinal Equity completed their purchase of Lockhart/Gardner debt." "They are invested in our financial health, and we intend to honor that commitment." "Mr. Hayden," "I understand your disappointment in losing a merger opportunity, but I do believe this purchase of debt suggests the financial community has faith in management." "Therefore, I have determined" "Ms. Lockhart and Mr. Gardner not be removed as managing partners and that they continue to work, with your guidance, toward financial health." "After the deadline, five weeks from now," "Mr. Hayden, then you might find a merger partner." "That's my ruling." "(door shuts) Escaped the executioner." "WILL:" "For now." "We can never meet a five-week deadline." "I know." "We talk to the new creditor." "Get an extension?" "(thunder rumbles)" "SIMONE:" "Alicia." "I'm so sorry we didn't get to have that breakfast." "Oh, me, too." "You heading out?" "Yeah, Louis has business, so... no rest." "Be seeing you soon." "And why's that?" "Oh, you didn't hear?" "I purchased the Lockhart/Gardner debt." "I'm your new creditor." "You two will be working together?" "That's fantastic."