Garcia places notice before May 4.
Smith's account puts it after that date.
Drafting and citations
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Notice / source basis
Garcia Dep. 118:4–12
Smith Dep. 44:12–20
Notice memorandum · v4
Garcia testified that the supplier knew of the defect before May 4, 2025. Smith testified that it knew only after that date. On May 2, 2025, Garcia emailed Smith the defect report. The email does not show when Smith received or read it.
Replaces v3, held for review. Both accounts. Written before the email arrived.
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Notice memorandum / inspect its basis
The draft attributes each account to the witness who gave it.
Garcia deposition · 118:4–12
“Before May 4.”
The supplier knew of the defect before May 4. Garcia attended the review meeting.
Smith deposition · 44:12–20
“Only after May 4.”
The supplier knew of the defect only after May 4. Smith relies on correspondence he reviewed.
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Notice memorandum · v4
Approved by Elena RiveraBefore it leaves
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Smith's account puts it after that date.
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