400.01. Strict Product Liability-Issues

400.01 Strict Product Liability--Issues [1] The plaintiff claims that he was injured [while using] [as a result of the use of] the [product name, e.g. hammer]. Plaintiff claims that there existed in the [product name] at the time it left the control of the defendant a condition which made the [product name] unreasonably dangerous in one or more of the following respects: [Set forth in simple form without undue emphasis or repetition those allegations of the complaint as to the conditions which are claimed made the product unreasonably dangerous and which have not been withdrawn or ruled out by the court and are supported by the evidence.] [2] The plaintiff further claims that one or more of the foregoing was a proximate cause of his injuries. [3] The defendant denies [that the [product] was ever in its control;] [that any of the claimed conditions existed in the [product name] at the time it was in its control;] [that any claimed conditions of the [product name] made the it unreasonably dangerous;] [that any claimed conditions of the [product name] was a proximate cause of plaintiff's injuries;] [and] [that plaintiff was injured to the extent claimed]. [4] [The defendant also claims that the plaintiff assumed the risk of injury in one or more of the following respects: [Set forth in simple form without undue emphasis or repetition the affirmative allegations in the answer which have not been withdrawn or ruled out by the court and are supported by the evidence.]] [5] [The defendant also claims that one or more of the foregoing was a proximate cause of the plaintiff's injury.] [6] [Plaintiff denies that he assumed the risk of injury and also denies that any assumption of risk on his part was a proximate cause of his injuries.]