Potential Client Interview Memo PDF

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Salmon, Trout & Haddock, LLP ▪ Two Union Square ▪ 42nd Floor ▪ 601 Union Street ▪ Seattle, WA 98101

MEMORANDUM To:

Scott L. Haddock, Attorney

From: Jennifer Robertson, Paralegal Date: July 18, 2014 Re:

Vidalia Unyon Case - Witness Interview of Ms. Nelda Nigalski Our File No.: 14U034

This is memorandum is in regards to our client, Vidalia Unyon, and her divorce case. On July 15, 2014, I interviewed a witness by the name of Nelda Nigalski. Below are my notes from that interview. Ms. Nigalski is 47 years old woman who is quite thin and about 5’8”. She has very straight, dry, long dark brown hair, with a noticeable gray part-line. She spoke rapidly and imperiously during our interview, and whenever we discussed Dr. Greene Unyon, our client’s estranged husband, Ms. Nigalski’s voice would go to a whisper, as if someone might overhear. Ms. Nigalski appeared to be a long-time smoker, with a deep, raspy voice. She reeked of smoke, and I found myself coughing just from the smell of her bland, brown and green clothing. Ms. Nigalski worked for Dr. Unyon’s office for about two and a half years as the receptionist. She spoke very highly of Dr. Unyon, calling him “the most respected veterinarian in the city.” She left his employment two months ago, and now works as a bank teller for a local bank where she earns more money. Ms. Nigalski stated that she cannot imagine how Dr. Unyon will get by in his veterinarian practice without her “expertise” and “dedication.” She referred to herself as “his girl Friday,” and asserted that she had to do all the real work because “the other employees were too lazy.” While Ms. Nigalski indicated that she respected Dr. Unyon as a practitioner, she also indicated that she detested his “philandering.” According to Ms. Nigalski, Dr. Unyon was always hitting on his female employees, “especially the young ones.” She confirmed that Dr. Unyon often spoke disrespectfully of his wife, calling her “the Virgin Mary” because of her strong religious views. She also stated that Dr. Unyon instructed her to put some female callers directly through to his personal line no matter how busy he was, and he frequently left the office early and in a hurry after such calls. Ms. Nigalski does not have any direct knowledge of any specific sexual activities by Dr. Unyon at the office, but she says that he frequently met with female employees in his office with the door closed, and for long periods of time. In addition, Ms. Nigalski told me that she has seen Dr. Unyon’s “little black book,” with the names of women and phone numbers in it. Back in February 2014, Dr. Unyon accidentally left the address

Scott L. Haddock, Attorney July 18, 2014 Page 2

book out on his desk, and Ms. Nigalski went through it. She confirmed that Georgia Peach’s name and telephone number were in this book, and next to Ms. Peach’s name were five stars. My impression of Ms. Nigalski is that she has strong romantic feelings for Dr. Unyon, although she did not confirm this, nor did I ask her about this directly. She seemed deeply jealous of the “young attractive women” in the office, which she said “got Dr. Unyon’s attention so easily.” My instinct is that she may be purposely exaggerating Dr. Unyon’s workplace conduct out of spite, since it does not appear that Dr. Unyon shares her romantic feelings. I question whether a jury would view Ms. Nigalski as a reliable or likable witness. She rarely made eye contact with me, and she never smiled. Her statements often seemed rooted in resentment and anger. Again, I think Ms. Nigalski has strong romantic feelings for Dr. Unyon, which may cloud her version of the truth. Moreover, Ms. Nigalski tended to raise her nose and speak down to me throughout our interview, as if she considered herself superior. She seemed to get defensive easily, as if she was constantly expecting to be contradicted. If you have any questions about this witness, please let me know. I have enclosed a draft of the declaration I have prepared for Ms. Nigalski to sign as well as my witness plan. Encls....