Casey
Inconsistency Analyst
11
Findings
3
Critical
3
High
5
Other
🔴 Critical
Case-Breaking Contradictions
1. Safety Training Denial vs. Signed Acknowledgment
⚡ 98% Impeachment Value
Claim
"Nobody ever told me about asbestos being dangerous. I never received any safety training about it."
Evidence
Exhibit AMS-049: Signed "Asbestos Hazard Training Acknowledgment" dated March 15, 1979, with plaintiff's signature confirming receipt of safety training and hazard materials.
📄 Delgado Depo, p. 34:12-18
📄 Exhibit AMS-049
Recommended Approach
Lock in denial firmly before producing document. Get witness to confirm they would remember signing something this important. Then confront with exhibit.
2. Respirator Denial vs. Equipment Checkout Records
⚡ 94% Impeachment Value
Claim
"They never gave us any respirators or masks. We had nothing to protect ourselves."
Evidence
Equipment checkout logs show plaintiff signed for respirator equipment 47 times between 1979-1983. Includes signature, date, and equipment serial numbers.
📄 Delgado Depo, p. 41:5-11
📄 Equipment Checkout Logs 1979-1983
Recommended Approach
47 instances is devastating. Establish pattern, not just single contradiction. "Sir, would it surprise you to learn you signed for respirators not once, not twice, but forty-seven times?"
3. Employment Dates: "5 Years" vs. Actual 3.5 Years
⚡ 89% Impeachment Value
Claim
"I worked at Atlantic Maritime for about 5 years, breathing in asbestos every single day."
Evidence
W-2 records and personnel file show employment from June 1978 to December 1981—exactly 3 years, 6 months. 30% shorter than claimed exposure period.
📄 Delgado Depo, p. 23:8-14
📄 W-2 Records
📄 Personnel File
Recommended Approach
Goes to exposure duration—critical for damages. "You inflated your exposure period by 43%. What else have you inflated?"
🟠 High
Strong Impeachment Material
4. Work Location Claims vs. Assignment Records
⚡ 82% Impeachment Value
Claim
"I worked exclusively in the boiler rooms where the asbestos exposure was worst. That was my station."
Evidence
Work assignment records show plaintiff rotated through 6 different stations: deck, engine room, cargo hold, electrical, boiler room (only 4 months), and general maintenance.
📄 Delgado Depo, p. 38:2-9
📄 Work Assignment Records
Recommended Approach
Undermines exposure intensity claims. Only 4 months in highest-exposure area vs. claimed "exclusive" assignment.
5. Job Duties Inflation
⚡ 78% Impeachment Value
Claim
"I was cutting and removing asbestos insulation daily. That was my primary job."
Evidence
Job description for "Pipe Fitter Helper - Class II" shows no asbestos removal duties. Insulation work performed by specialized contractor (Bayshore Insulation Inc.) per union agreement.
📄 Delgado Depo, p. 45:14-22
📄 Job Description Records
📄 Union Agreement - Insulation Work
Recommended Approach
Shows exaggeration pattern. His job category explicitly excluded the work he claims caused his exposure.
6. Coworker Testimony Contradiction
⚡ 75% Impeachment Value
Claim
"Nobody in our crew got respirators. Ask anyone who worked there—we were all unprotected."
Evidence
Coworker depositions (Hartley, Morrison, Chen) all confirm receiving respirator equipment and training. Hartley specifically recalls plaintiff complaining his respirator "didn't fit right."
📄 Delgado Depo, p. 54:18-24
📄 Hartley Depo, p. 28:3-12
📄 Morrison Depo, p. 15:8-19
Recommended Approach
Plaintiff invited corroboration ("ask anyone"). His own witnesses contradict him. Hartley's specific memory of fit complaint is devastating.
🔵 Moderate
Supporting Inconsistencies
7. Ship Name Confusion
⚡ 65% Impeachment Value
Claim
"I remember working on the USS Coral Sea. Spent months on that ship."
Evidence
Atlantic Maritime vessel records show no contract for USS Coral Sea during plaintiff's employment. Work logs show assignments to SS Atlantic Merchant and SS Pacific Trader only.
📄 Delgado Depo, p. 44:2-8
📄 Vessel Contract Records
Recommended Approach
Memory/credibility attack. If wrong about which ships, what else is wrong? Useful for pattern, not standalone.
8. Supervisor Name Error
⚡ 58% Impeachment Value
Claim
"My supervisor was Bob Richardson. He should have given us safety training."
Evidence
Personnel records show supervisor was Robert Richards (not Richardson). Additionally, Richards wasn't responsible for safety training—that was Safety Officer Thomas Mueller.
📄 Delgado Depo, p. 26:11-15
📄 Personnel Org Charts
Recommended Approach
Minor but useful for cumulative effect. "You don't remember your supervisor's name, but you're certain about events from 45 years ago?"
9. Symptom Onset Timeline
⚡ 61% Impeachment Value
Claim
"I started having breathing problems right after I left Atlantic Maritime in 1985."
Evidence
Medical records show first respiratory complaint in 2019—36 years after employment ended. No respiratory visits 1983-2019 across three physicians.
📄 Delgado Depo, p. 67:4-12
📄 Medical Records 1983-2019
Recommended Approach
"Immediate symptoms" claim is provably false. Suggests exaggeration pattern even though 2019 onset is consistent with mesothelioma latency.
⚪ Minor
Background Inconsistencies
10. Age at Hire Discrepancy
⚡ 35% Impeachment Value
Claim
"I was just 18 years old when I started. Just a kid who didn't know better."
Evidence
Birth certificate shows DOB 3/15/1957. Employment began 6/1978. Plaintiff was 21 years old at hire, not 18.
📄 Delgado Depo, p. 19:5-8
📄 Birth Certificate
Recommended Approach
Low value standalone. Use only as part of cumulative credibility attack.
11. Job Title Variation
⚡ 32% Impeachment Value
Claim
"I was hired as a Pipe Fitter. That was my title from day one."
Evidence
Initial hire paperwork shows "General Laborer" for first 8 months. Promoted to "Pipe Fitter Helper - Class II" Feb 1979. Never held "Pipe Fitter" title without "Helper."
📄 Delgado Depo, p. 21:18-22
📄 Hire Paperwork
Recommended Approach
Supports job duties inflation (#5). "Helper" distinction matters for exposure claims. Use in combination.