Actual project records, decisions and informed explanations may help establish what the employee knows. Their usefulness depends on their substance and reliability.
Reconstruct the history honestly
Identify dated work examples and people who can explain them firsthand. Mark retrospective explanations as such instead of creating documents that appear contemporaneous. Preserve enough technical context for review while respecting authorized disclosure and secure handling requirements.
The distinctive cost in a manufacturing case is the internal effort of turning a quality system into a petition exhibit: locating protocol revisions, retrieving validation and deviation records, assembling training matrices, and having a senior person write and sign a considered statement. The material worth preserving is specific: qualification records for procedures developed in-house, revision histories that show who authored what and when, training material written internally, purchase and modification records for equipment adapted to a particular use, and job files linking the person to the work.