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From the deposition of Larry Setchell We came to believe early on that 11 Mr.

Seegmiller's crash happened because a cargo strap 12 that had been used to tie down a dog box on the back 13 of the ATV somehow came loose. We came to believe 14 that that cargo strap got loose and wrapped around the 15 rear axle, and we came to believe that because the 16 cargo strap wrapped around the rear axle, that locked 17 up the rear axle. And, you know, to be specific, it 18 was the left rear axle'. And that, in turn, caused all 19 four wheels of the ATV to lock up suddenly. We came to think and believe that there were 21 two main defects involved. One had to do with the 22 idea that that left rear axle was not guarded. You 23 know, in the go-cart world, for example, they have 24 25 little tubes that go around the live axles to prevent children's hair from getting wrapped up in that live axle and thus avoiding horrible accidents. 2 In the ATV world some manufacturers had 3 structural guards around the rear axle. Some did not. 4 None of them claimed it was for safety reasons, but we 5 felt that it was a good idea and it would have 6 prevented Mr. Seegmiller's crash. 7 The second defect was a little more, you 8 know, engineering think, engineering speak, in that 9 when all four wheels lock up and it surprises the 10 operator, the operator doesn't have a tool left to 11 control the ATV. So at least the engineers that I 12 worked with and I thought that that was a serious 13 enough defect which if had not been present in this 14 Honda ATV would have allowed Steve Seegmiller to have 15 control at least of the front wheels. Yeah, it did not put the brakes on the front 2 axle, as -- as you asked, but it did lock up the front 3 axle as well, having the same effect as if all four 4 wheels had, you know, been applied brakes at the same 5 time.