Examination plan
Smith’s examination
You testified that the supplier learned of the defect “Only after May 4.” What correspondence did you review before giving that answer? (Smith Dep. 44:12)
Garcia testified that the supplier knew “Before May 4.” How do you account for that testimony? (Garcia Dep. 118:4)
Proposed exhibit: the May 2 email with defect-report.pdf. Do you recognize it? When did you receive it, and when did you first read it? (defect-email.eml)
Receipt and reading remain unconfirmed. Request Smith’s copy, delivery records and the review-meeting notes.