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A delivery driver sued a forklift manufacturer after a warehouse forklift rolled backward and crushed his foot. The manufacturer denies that the brake design was defective and argues that the driver's employer failed to maintain the forklift. The driver offers three categories of evidence.
First, the driver offers maintenance records showing that the forklift passed inspection two weeks before the accident. Second, he offers reports of four prior rollaway incidents involving the same forklift model at other warehouses, each occurring on a mild incline while the operator was loading pallets. Third, he offers 12 graphic surgical photographs of his crushed foot. The manufacturer offers to stipulate that the driver suffered a severe foot injury and that he needed surgery, but it disputes defect and causation.
The manufacturer objects under Rules 401 and 403. Analyze the admissibility of each category of evidence, including relevance, probative value, unfair prejudice, cumulative proof, and possible alternatives.