Extract to table

Vlahos must be thoroughly familiar with the operating data for the turbocharger in the weeks and months before the failure and must be prepared to explain, with specificity, why any observed variations did not indicate an impending failure

During the preparation session, we must ask Vlahos directly whether any such communication exists and review all relevant documents carefully

Nevertheless, Vlahos's factual testimony must independently support the latent defect defense, and his account of the facts must be consistent with the conclusions that Dr

Regarding the auxiliary boiler failure, TSL's position on whether it was causally linked to the BWTS issue or an independent failure must be clarified and consistently presented

During the preparation session, all of these documents must be reviewed with Vlahos in detail

Key Points for Testimony Vlahos's testimony on Incident 2 should emphasize: • The BWTS was functioning normally before the intake of contaminated ballast water at the prior port; • The contamination was the proximate cause of the BWTS malfunction; • The contaminated ballast was loaded at a port selected by Northwind or Northwind's agents as part of the vessel's trading pattern under the charter-party; • Any contemporaneous documentary evidence supporting the contamination theory — ballast water records, engine room logbook entries, communications with shore-side or with the BWTS manufacturer; • On the auxiliary boiler failure, Vlahos should be straightforward about the nature of the failure and any independent maintenance issues, but should clearly distinguish the boiler failure from the BWTS problem if they are unrelated; • Vlahos's account of Incident 2 must be consistent with the testimony given by Capt