available, citing both the Hernandez and Boatland cases. Indeed, because product liability claimants must prove a safer “alternative” design, see Tex. Civ. Prac. & Rem.Code Ann. § 82.005, it would be absurd to limit discovery to the specific model at issue because that would necessarily preclude discovery on alternativ 4-R, 2007 WL 2712925, at *5, 2007 U.S. Dist. LEXIS 67973, at *15 (W.D.Ky.2007) (order) (“Information concerning prior models of GM U-Vans would remain relevant to issues of defect, notice of defect and GM’s possible failure to respond to an alleged defect; whereas, discovery of information related to later models would remain relevant to reasonable alternative designs and them performance.”); Mann ex rel. Akst v. Cooper Tire Co., 33 A.D.3d 24, 816 N.Y.S.2d 45, 55 (2006) (<HOLDING>); Cardenas v. Dorel Juvenile Group, Inc., 230
holding that scope of discovery in tread separation case should include documents relating generally to the tread separation defect or problem because otherwise the defendant would not produce documents probative on the issues of notice defectiveness and dangerousness holding that pursuant to the best evidence rule trial testimony relying on documents was inadmissible without submission of such documents or an explanation as to why the documents were unavailable recognizing separation of powers doctrine holding that the agency did not have an obligation to search for and produce the documents the plaintiff claimed entitlement to because the plaintiffs foia request gave no indication that she sought those particular documents recognizing a referendum on a court judgment would violate separation of powers