Document 6BpDapbg54Nrr3QOk5QeN93nR

Page 3872 1 instruction, and the reason we would do so is because 2 of the facts of this case. 3 By its very nature friction products are an 4 expendable or renewable product, and I think just the 5 way the continuing duty to warn instruction is phrased 6 and as given, it leads to some kind of confusion 7 because -- especially with respect to the facts in the 8 Wood case where the vehicles were so much -- so old by 9 the time Mr. Wood started at the post office. 10 I think that the continuing duty to warn 11 instruction confuses the issue on that and it may lead 12 the jury to believe that there doesn't have to be 13 actually any Ford friction products on the truck in 14 order for them to judge liability. 15 I would just request that maybe there be a 16 one-sentence additional instruction to the jury 17 indicating that they should not consider the 18 continuing duty to warn instruction to prevent the 19 requirement that they actually have to find that the 20 plaintiffs were exposed to brake and clutch parts 21 supplied or manufactured by Ford.