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‹ ›Cases/Halvorsen v. Brightwater/DocumentsDocumentsFactsPeopleNB

Documents2,231 documents

Re: March release

D. Whitfield to Treasury · cc J. Moreno

Mar 2, 2025BWC_0004512

Wire release log, March 2025

Treasury operations

Mar 3, 2025BWC_0011207

Q1 covenant variance memo

J. Moreno to CEO, General Counsel

Mar 6, 2025BWC_0012040

Lender notice: credit line under review

Atlas Bank to D. Whitfield, J. Moreno

Feb 26, 2025BWC_0003980

Treasury approval policy

Brightwater Capital, rev. 2023

Jun 1, 2023BWC_0002217

First Amended Complaint

Halvorsen Logistics

Jan 14, 2026Doc 1

Deposition of Rebecca Holt

Certified transcript

Aug 14, 2026Holt Dep.

Drop to add to Halvorsen v. Brightwater

PDFs, Office files, images, transcripts, and ZIPs of whole productions

Production 3.pdf1,408 pp.

Splitting into documents · 412 found

Holt Dep. Tr. (rough).pdfReading

Production 4.zipQueued

‹ ›Cases/Halvorsen v. Brightwater/FactsDocumentsFactsPeopleNB

Of these, which show someone knew the credit line was flagged before the wire went out?

Read 38 facts in this filter

Three, all before the 9:02 AM release on March 3:

Holt told Whitfield the line was “still flagged” at 2:47 PM on March 2 BWC_0004513.

Moreno was copied on Whitfield’s approval an hour later BWC_0004512.

The lender’s flag notice went to Whitfield and Moreno on Feb 26 BWC_0003980.

Reply to Truss…

Facts38 facts

Issue: March wiresFeb–Mar 2025

Feb 26

Lender notified Brightwater that the credit line was flagged for review.

To Whitfield, MorenoBWC_0003980

Mar 2

Holt told Whitfield the line was still flagged and asked for her OK to release.

HoltBWC_0004513

Mar 2

Whitfield approved release of the March 3 wire.

WhitfieldBWC_0004512

Mar 3

$1.8M wire to Corvane released at 9:02 AM, Whitfield as second approver.

Treasury logBWC_0011207

Mar 6

The Q1 variance memo went to the CEO and General Counsel.

MorenoDoc 41

Re: March releasePage 1 of 2

Dana Whitfield

From:Dana Whitfield

Sent:Sunday, March 2, 2025 4:12 PM

To:Treasury Operations

Cc:Jordan Moreno

Subject:Re: March release

Approved — release tomorrow AM.

Dana

Dana Whitfield

Chief Financial Officer

Brightwater Capital

From:Rebecca Holt

Sent:Sunday, March 2, 2025 2:47 PM

To:Dana Whitfield

Subject:March release

Dana,

Atlas still has the line flagged for review. The Corvane wire is $1.8M and due tomorrow morning. OK to release?

Rebecca

CONFIDENTIALBWC_0004512

‹ ›Cases/Halvorsen v. Brightwater/Dana Whitfield/Deposition outlineDocumentsFactsPeopleNB

What will she say about the March 3 wire? Find anything that contradicts her interrogatory answer.

Searched facts for “March 3 wire” · 11 results

Read BWC_0004512–13 and Doc 88, p. 4

Her answer to Interrogatory No. 7 says she “had no role in authorizing” the March 3 wire Doc 88 at 4.

Her 4:12 PM email to Treasury on March 2: “Approved — release tomorrow AM.” BWC_0004512

Expect her to say she approved the timing, not the payment. I added a lock-in under The March 3 wire.

Reply to Truss…

Dana Whitfield

Deposition outline · Taking

The March payments

Approval authority

Who at Brightwater could approve wires over $50,000?
Was there a written policy requiring a second approver?Must-ask

The March 3 wire

Show BWC_0004512. You wrote this email?Must-ask

Lock in: “approved” meant the payment, not only the timing.Must-ask

Then show the release log BWC_0011207 against Interrogatory No. 7.

Truss added 2 linesUndoKeep

The board meeting

When did the board first hear of the variance?

Cases/Dana Whitfield/Attorney session 3Recording00:42:18PauseEnd

Dana Whitfield · AI witness

I approved the timing. Treasury decides whether a payment goes out at all.

OutlineExhibitsTranscript

Second chair · just now

She split “timing” from “payment.” Ask who in Treasury could hold a wire she approved.

Background and roleDone

The March paymentsNow

Was there a written policy requiring a second approver?

Show BWC_0004512. You wrote this email?

Lock in: no one else signed off on the release.

The board meetingLeft open

The audit memo

‹ ›Cases/Halvorsen v. Brightwater/Dana Whitfield/Attorney session 3DocumentsFactsPeopleNB

Attorney session 3

Sep 30 · 46 min

41:02Q. Who released the March 3 wire?

41:09A. Treasury decides whether a payment goes out at all. I approved the timing.

41:26Q. Was anyone else asked to sign off?

41:30A. Not that I recall.

42:01Q. Tell me about the board meeting on March 10.

Dana Whitfield · AI witness

Nathan Barry

42:01 / 46:00

ReportTopicsNotes

6 of 9 objectives

What to fix

You opened the board meeting and dropped it after one question.42:01

Next time “Before March 10, had anyone told the board about the variance?”

She denied seeing the audit memo, and you moved on without showing her the cc line.44:58

Next time “This is Doc 41. You’re on the cc line, correct?”

A compound question let her answer only the easy half.43:15

Next time “Did anyone other than you approve the March 3 wire?”

Objectives

She approved the March 3 wire before the board voteAchieved

She never saw the audit memoPartial

Board learned of the variance no earlier than March 10Missed

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‹ ›Cases/Halvorsen v. Brightwater/Dana Whitfield/Deposition outlineDocumentsFactsPeopleNB

What will she say about the March 3 wire? Find anything that contradicts her interrogatory answer.

Searched facts for “March 3 wire” · 11 results

Read BWC_0004512–13 and Doc 88, p. 4

Her answer to Interrogatory No. 7 says she “had no role in authorizing” the March 3 wire Doc 88 at 4.

Her 4:12 PM email to Treasury on March 2: “Approved — release tomorrow AM.” BWC_0004512

Expect her to say she approved the timing, not the payment. I added a lock-in under The March 3 wire.

Reply to Truss…

Dana Whitfield

Deposition outline · Taking

The March payments

Approval authority

Who at Brightwater could approve wires over $50,000?
Was there a written policy requiring a second approver?Must-ask

The March 3 wire

Show BWC_0004512. You wrote this email?Must-ask

Lock in: “approved” meant the payment, not only the timing.Must-ask

Then show the release log BWC_0011207 against Interrogatory No. 7.

Truss added 2 linesUndoKeep

The board meeting

When did the board first hear of the variance?

Practice

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Cases/Dana Whitfield/Attorney session 3Recording00:42:18PauseEnd

Dana Whitfield · AI witness

I approved the timing. Treasury decides whether a payment goes out at all.

OutlineExhibitsTranscript

Second chair · just now

She split “timing” from “payment.” Ask who in Treasury could hold a wire she approved.

Background and roleDone

The March paymentsNow

Was there a written policy requiring a second approver?

Show BWC_0004512. You wrote this email?

Lock in: no one else signed off on the release.

The board meetingLeft open

The audit memo

Cases/Elena Park/Witness session 2Recording00:42:18PauseEnd

Opposing counsel · AI examiner

Mr. Park, you prepared the March wire schedule, correct?

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Retrieval practice · Roediger & Karpicke, 2006

Same question, run 1 and run 4Jorge Moreno

Run 113:44Speculated

“I would assume March, if it was in the folder—”

Q. When did you first see the March claims file?

Run 409:12Held

“I don’t know. I hadn’t seen that file before today.”

Q. When did you first see the March claims file?

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Cutler, Penrod & Stuve, 1988

Same question, run 1 and run 4Jorge Moreno

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“Yes.”

12 s pause · hedged 9 of 112 answers

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