The district court judge ruled that since the ladder was being offered as a demonstrative exhibit, the plaintiff’s objection to untimely disclosure was irrelevant. Cuprum also argued that the exemplar ladder would be used to demonstrate and help the jury understand the expert’s testimony. It was not intended to be substantive evidence. In response to the objection, Cuprum argued that the exemplar ladder was for demonstrative purposes and that it would be used during direct examination of its expert witness. ![]() The ladder had not been included in Cuprum’s expert disclosures. 1, 2011, Cuprum’s exemplar ladder was marked as an exhibit “for Demonstrative Purposes.” The plaintiff’s counsel objected to any use of the new exemplar ladder at trial. The exemplar ladder was new, but had been built to the exact specifications to the ladder that Baugh had used. John could not testify as to what happened to him because of his injuries.Ībout three months before the beginning of the trial, the defendant, Cuprum, informed plaintiff’s attorney that it intended to use an exemplar of the actual ladder at the jury trial. claiming that the defective design and the manufacturer’s negligence was the cause of her husband’s injuries. Baugh’s wife Sharon filed a lawsuit on his behalf against Cuprum S.A.de C.V. Completely functional.John Baugh sustained a severe brain injury when the Cuprum ladder that he was using to clean his gutters buckled and collapsed. Duty rating 250 lbs.Slight bend in overall straightness. total length, 29' maximum working length, 24' 8" highest standing level. Type 1 Heavy Duty Industrial Model D1532-2 32 ft. Werner aluminum 32 foot extension ladder.
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