The Many Faces Of Fredo, Or, Due Diligence When The Godfather Comes Knocking – Part Two: Dangerous Women


by Tara J. Lamer

Last week, we learned that your client is interested in going into business with an exciting Las Vegas club owner and fantastic host named Frederico Corleone. Now, you have no choice but to start deciding where to take this diligence investigation, how far to go, and how much to spend.

 

I just need basic background, nothing fancy, stick to what you can get online and in your databases.

 

The lower budget version of an investigation will tell you the Frederico “Fredo” Corleone is married, owns a nightclub, owns a house, has no arrests in Nevada, has no history of being personally named in employment litigation, has never had a tax lien or declared bankruptcy, and has a modest social networking presence dedicated mostly to his glamorous lifestyle and his pets. (Yes, he is originally from New York, but he has lived in Nevada for years, so yes, for now you want to keep the scope to Nevada only because this case budget is blowing up.)

 

This is all consistent with the charming person your client was entertained by at Fredo’s club, and since your client has told you “no one has a single bad word to say about him,” seems like you have a picture of who he is and your client has some things to put into the file.  Diligence performed.

 

But is that really the point?  Are you simply padding a file or are you really interested in the outcome of this partnership?

Do you know anyone in this world who is truly an island unto himself?

 

Should we narrow this to Mr. Corleone or would you also like us to investigate his spouse? This adds to our time budget.

 

The next step up in this budget is likely Fredo’s spouse. Through a basic online and database investigation, you learn Deana Dunn-Corleone is an actress, she is close friends with famous singer Johnny Fontane, and she even won an Academy Award.  This seems like a plus mark in the pro-Fredo column, because who does not like beautiful celebrities?  Now your client can say they are in business with a famous actress, and may even be able to post some photos with her!

 

This may all be true. However, let’s take a moment to think this over.  What is your client’s exposure tolerance on this deal?

 

Would it matter to anyone that Deana probably has interactions with the media?  That she sometimes has paparazzi following her?  Perhaps to a meeting place where your client may also be?

 

Is that a positive or a negative?

 

If your client likes the idea of free publicity, or does not really care either way, you might be finished here. However, this makes the assumption that Deana will be a benefit – that she will always behave herself, and that most importantly she can be trusted with potentially sensitive business information she comes by simply by virtue of being married to your client’s prospective business partner.

 

Next week we are going to look at how you figure out whether Deana is a dangerous woman, and without giving too much away, how you may learn some surprising new information about your new friend Fredo.

Tara J. Lamer

Tara joined Smith & Carson as an Investigator in 2014, and focuses on product liability and business litigation. Prior to joining Smith & Carson, she represented Fortune 100 clients in products and premises liability cases. Tara has extensive experience in fact and expert witness development, alternate causation and non-use defenses, multi-jurisdictional case management, e-discovery, and mass tort technology development. She has taught continuing education on effectively defending exigency demands and wrongful death cases filed in high-volume jurisdictions. Tara is a graduate of the University of Missouri-Columbia School of Law and is a licensed Attorney in Missouri. She holds Private Investigator licenses in Missouri and Kansas.