safely as an ordinary consumer would expect when used as intended or in a manner reasonably foreseeable by the manufacturer] and (the product) reached (claimant) without substantial change affecting the condition in which it was sold and, if so, whether that failure was a legal cause of the [loss] [injury] [or] [damage] to (claimant, decedent, or person for whose injury claim is made).
e., Strict Liability - Failure to Warn:
whether the foreseeable risks of harm from (the product) could have been reduced or avoided by providing reasonable instructions or warnings and the failure to provide those warnings made (the product) unreasonably dangerous and, if so, whether that failure was a legal cause of the [loss] [injury] [or] [damage] to (claimant, decedent, or person for whose injury claim is made).
*800 f. Negligence:
whether (defendant) was negligent in (describe alleged negligence), and, if so, whether that was a legal cause of the [loss] [injury] [or] [damage] to (claimant, decedent, or person for whose injury claim is made).
g. Negligent Failure to Warn:
whether (defendant) negligently failed to warn about particular risks involved in the use of (the product), and, if so, whether that failure to warn was a legal cause of the [loss] [injury] [or] [damage] to (claimant, decedent, or person for whose injury claim is made).
403.16 ISSUES-QN CRASHWORTHINESS AND "ENHANCED-I-NJ-tJ-RY"-CLAIMS
(RESERVED)
[In addition, - there is a second set of issues-you must-al-so decide- in this cased* (Claimant) [next] claims [he][she] -suffered [greater-]- [or].[additional]- injuries in-the accident than-[-he][-she] -would have-otherwise suffered if (describe the -alleged crashworthiness-defect) had-not-been-defective? - (Claimant)- does not claim that (describe the alleged crashworthiness defect) caused the accident,**
1⁄8-Use - the - br-aeketed - language -when there are other-defect claims in the case.
-**The defendant-is entitled to have the ¿jury instructed on this last sentence "when appropriated - D-Amaño v.-Fori - M-etor-Co., -806-So?2d-4-2A4Fla.-2001-)?
The issues you must decide on this-c-laim are-whether (describe the alleged-defective part-of-the product) was defective-andr if so,-whether- that- defect was a legal cause of-[-loss-]-[injury]-[or] [damage] to (claimant, decedent, -or-person for whose injury claim is made)-that-was [greater than]-[or] [additional to that-which] [he][she]-woald have suffered-jf (describe the-alleged defective par-t-of-the product)-had-not been defective?
A producb-is- defective if it -is-unreasonably dangerous when it leaves-the-possession -of-the [manufacturer] -[-seller] [distributor] [supplier-]- [importer] [defendant] and the product-reaches the-user- or-consumer without substantial change affecting that condition?
A product-is- unreasonably-dangerous-to [the user] [a-person in- -the-vicinity of the productj-Mf-t-the -product fails~to-perform as safely as an ordinary-consumer would expect when-used as - intended - or when used -in-a-manner reasonably--foreseeable by the-[-manufacturer] [selIer]-[-dlstributor] [supplier] [importer]].-
* When the injured person-is-a-bystand- or, use the-language in the-seeead set-of brackets? - See-Wcsi v. Caterpillar- Tractor Co., Inc., 336 -So.2d 80 (Fla.1976), and Sanchez-v.-H-ussey Seating Co.,--698-So?2d 1326 (Fla. 1st DCA 1997). See-4Q3?-7-note 2-
Normally a defendant is responsible-for only [loss] [injury] [or] [damagej-eausedby its product-and not the-actions of others. If you find that the (describe-the-alleged defective- part of the product)-was defective and-that defect caused-[loss-]-[injury] [or] - [damage] - to - (claimant) - that - was [greater- - than] - [or] - [additional-to - that which] would-have resulted-from the accident if (describe