Document 7Rn3x30yeKDOXONmmOk0peOyV

1 negligent in failing to warn users, consumers, Page 3777 2 mechanics, et cetera, about the need to take 3 precautions during the replacement of brake materials 4 to prevent dust from being released and being breathed 5 into the air. 6 That is why our verdict form looks 7 different, I know, from the Grewe verdict form and 8 from verdict forms that have been submitted in the 9 past. 10 I will also tell Your Honor, and I told Mr. 11 Williams this, I am also concerned about the 12 possibility, given the specifics of the Wood case, 13 creating the possibility of an inconsistent verdict 14 with the jury given the problems and concerns I have 15 with the negligent instructions that Your Honor gives 16 and the strict liability instructions. 17 I think from reading the past instructions 18 that we have done many times together, I think your 19 instructions are proper for negligence and strict. 20 The problem I have is that I don't think we 21 can meet the test for strict liability. Rather than