An emergency courtroom is set up in a hospital conference room. Will represents Kate Willoughby, whose unborn child requires an in-utero surgical intervention on its heart. Lifestate, Kate’s insurance provider, has put a stop to the surgery two days before it’s scheduled because they don’t cover experimental procedures. SLG is also in charge of a class action lawsuit against Lifestate and the case with the Willoughbys would set the precedent for the 68 other cases where Lifestate denied coverage. Lifestate’s lawyer offers Will a deal, drop the class action suit and they’ll find the money to save her baby, but Will says no. When it looks like the outcome will be in favor of Kate, Lifestate’s defense claims that Kate’s husband inaccurately filled out their application for coverage and thus voids their contract for insurance. With Kalinda’s help, Will gets leverage on Lifestate’s unethical practices. Those unethical practices include a separate branch of Lifestate employes, PAM, or Policy Application Management a group of Lifestate employees who look for policy issues only after expensive claims have been filed. This sort of group is illegal in some states and will be soon in Illinois, and rather than the information becoming public, a settlement is reached and the baby’s surgery is a success.
On the personal front, Peter continues to repair his reputation through religion; while at the office, Alicia and Will share a kiss which leads to Alicia sleeping with Peter. The next day when Will questions Alicia for returning to his office after the kiss she denies any remaining feelings for him. Will parts by stating "We had bad timing, we've always had bad timing."