Extract to table

Captain Giannopoulos must be able to testify to specific conditions—wind speed, wave height, current patterns, tropical weather systems, or other hazards—that informed his decision

If Stavridis testified that the decision was the Master's, Captain Giannopoulos must confirm that account

If Stavridis's testimony was ambiguous or potentially inconsistent on this point, we must be prepared to navigate the discrepancy carefully during the deposition and, if necessary, during the preparation session

The Captain must be cautioned not to speculate about TSL headquarters' commercial motivations for having cargo available at Maputo

Anticipated Questions: Plaintiff's counsel will likely explore the following topics in connection with Incident 3: • The prior maintenance history for the cylinder liners, including the dates of last replacement, inspection, and measurement • Chief Engineer Vlahos's recommendations regarding cylinder liner condition and any reports to TSL headquarters recommending replacement or refurbishment • Whether there were any prior warning signs—such as excessive wear measurements, lubricating oil analysis results, or performance degradation—that should have prompted earlier replacement • Why the failure occurred when it did and whether it could have been prevented through timely maintenance • The decision-making process regarding the drydocking at Keppel Verolme Shipyard, including whether other repair options were considered and rejected Preparation Points: Because TSL has conceded liability on this incident, the witness must be carefully prepared to testify truthfully about the maintenance history without overreaching in denying maintenance shortcomings

Critical Caution: The witness must be firmly instructed not to volunteer information that could undermine TSL's position on Incidents 1 and 2