Agree, my point was not about the production records here, but that I would expect the design owner to have some documentation that shows that a design transfer occurred and that this activity was planned and verified or validated as appropriate. To understand this is important for the OP as it will be a very bad start for the audit when the auditor hears something like "Oh, there was no design transfer because...". Even if later on all necessary documentation will be found the auditor will get the impression that there is a lack of knowledge regarding the requirements of ISO 13485.