Document MMOnqE6Ljn0L9jwxEKybbeV3z

2 when I talked to him about it on cross-examination, 3 but in addition to the Ford owner's manual, the Ford 4 technical service manual, Ford also had what is called 5 a service manual, and we have that for 1946 cars and 6 trucks. 7 Within that, there is a section pertaining 8 to servicing brakes which basically deals with 9 removal, removing the wheel and drum assembly. 10 And there is a note. When removing rear 11 brake shoes, it will be necessary to remove the 12 retainers and washers with hold and hand brake linkage 13 and remove the linkage, nothing further or any 14 warnings of any type. 15 Ford Motor Company knew that on the 16 installation of brakes as well as when removal of 17 brakes, that they would create dust and as a result of 18 that they had a duty to warn about the dangers of 19 asbestos. 20 What I would like to do is also on the 21 overhead and also as a board in case it is easier to 1 read on the board, is what the Judge has given you in 2 his instruction verbatim, should be verbatim to what 3 he has given you with respect to the duty of a 4 manufacturer to warn. 5 What this basically says is if despite 6 exercising reasonable care in the design, 7 manufacturing, testing, and inspection of the product, 8 and in this case the asbestos-containing truck, the 9 product still cannot be made safe for its reasonably 10 foreseeable use, and the manufacturer knows or through 11 the use of reasonable care should know that the 12 dangerous condition is not obvious to the user of the 13 product, is not obvious to Mr. Grewe or to Mr. Wood, 14 the user of the product, then that manufacturer Ford 15 Motor Company has a duty to give an adequate warning 16 of the danger. And a failure to fulfill that duty is 17 what the law calls negligence. 18 And we know that in the technical bulletin 19 by Ford that I showed Mr. Anderson that they did have 20 some warnings in there. 21 These are the warnings that they had in the 1 technical bulletin. 2 I have highlighted it. Before washing the 3 car, pull the hand brake lever all the way back. This 4 prevents water getting between the brake lining and 5 drum. 6 The second warning was when greasing the 7 chassis, do not overlook the lubricator fitting on 8 both rear brake camshafts. It is located at the rear 9 of the brake camshaft bracket just above the radius 10 rod.