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Rebecca,

I see you were added to the Meridian matter this morning — welcome aboard.

Attached are the case memo, order of proof, and chronology to get you oriented. Let me know if you want to dig into anything.

Daniel Hargrove is the pressure point for this matter. Meridian's defense rests on him lacking the skills to extract Pinnacle's design data, but the record keeps contradicting that story — his engineering credentials, his patent work, and the bulk portal exports from his own account. Every contradiction Meridian commits to traces back to him.

Attached are our key player summary for Hargrove, the in-progress impeachment sequence outline, and the related order of proof entry targeting his misconduct.

In their Answer and Affirmative Defense, Meridian Design Group asserts that "Daniel Hargrove is not an engineer and does not have the technical skills necessary to interpret structural engineering calculations or conduct systematic extraction of design data from Pinnacle's project portal."

Can you check Hargrove's background and see if this is true?

Sarah,

Attached is my report that concludes Meridian's assertion is demonstrably false.

Publicly available records indicate Hargrove holds a B.S. in Structural Engineering from Whitfield Polytechnic Institute, is a named co-inventor on a U.S. patent involving a multi-axial load distribution analysis method implemented in ANSYS Mechanical, and publicly describes himself as a "concept-through-construction" structural design leader.

The report also notes Meridian's own discovery responses appear to undermine its position by acknowledging that Hargrove reviewed foundation load schedules and referenced standard bearing-capacity tables in Pinnacle's published case studies.

The report includes preservation recommendations, a phased deposition outline, and targeted discovery requests.

Laura,

Meridian's opposition, filed this morning, asserts that no one at Meridian accessed Pinnacle's project portal before the licensing agreement was signed.

That conflicts with MDG-004127, the portal audit log Meridian itself produced. It shows 41 bulk exports from Hargrove's account in the six weeks before signing, and it is already cited in the order of proof under misappropriation.

I think the best play is to have their corporate witness commit to the assertion at Thursday's 30(b)(6) deposition, then use it as part of an impeachment sequence at trial.

Attached are the opposition, the audit log, and the current order of proof.

Attached is the updated outline. The access phase now opens with three commitments to lock in:

1. Who at Meridian held credentials to Pinnacle's project portal before the licensing agreement was signed?

2. Did anyone at Meridian view, download, or export Pinnacle design data before signing, in any format and for any reason?

3. Does Meridian stand by its opposition's statement that no design data was accessed before the agreement was signed, without qualification?

Their response to Interrogatory No. 14 repeats the assertion nearly verbatim. I noted both cites in the matter memo.

Once I have the deposition transcripts, I'll fold their commitments into our impeachment sequence outline.