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Deposition summary
Henrietta Vance — Director of Quality
Grounded
Themes
Pre-recall awarenessWarranty return thresholdsRecall decision timing
Key admissions

Witness confirmed she initialed the August QA dashboard on September 14, four weeks before Apex issued the recall notice.

Witness initially characterized the August lot returns as “within our normal warranty range” before conceding the rate was more than three times Apex's 0.4 percent investigation threshold.

Witness acknowledged no formal investigation was opened until October 11, the same day the recall was issued, despite the dashboard flagging the lot in early September.

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