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Modal verbs can't vrs couldn't?

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Hi everybody! Could you help me to feel the difference between can't and couldn't. 1. "Sarah couldn't have got my message. Otherwise she would have replied. " Here we are speaking about the PAST. We are sure that Sarah didn't receive the message yesterday, 1 hour ago, 1 minute ago. So she hasn't recieved the message yet. 2. "He can't have recieved my letter because I only posted it yesterday." Her we are also speaking about the PAST. My question: why have "couldn't" been used in the 1-st case, and why have "can't" been used in the 2nd case. In both cases we speak about the PAST.

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