40.  The allegations in all previous paragraphs are incorporated by reference as though  fully set forth here.   41.  Defendants owed a duty to all Plaintiffs and Class Members to exercise  reasonable care in the manufacture and distribution of the Sleeper.   42.  Defendants had a heightened duty of care to all Plaintiffs and the Class Members  because of the great danger associated with the Sleeper and the especially high risk of injury to  infants.   43.  Defendants breached that duty when they failed to take appropriate steps to ensure  the safety and integrity of the Sleeper.   44.  As a direct and proximate result of Defendants’ failure take appropriate steps to  ensure the safety of the Plaintiffs and the Class Members have suffered legal injury and damages,  8  in an amount to be proven at trial, including, but not limited to diminution of value of real estate,  loss of income and other economic loss, and loss of enjoyment of real property.   45.  The injuries were caused by the joint negligence of the Defendants.   46.  Upon information and belief, Plaintiffs allege that their injuries were the result of  Defendants’ joint negligence in:  a.  Failing to properly manufacture and/or distribute the Sleeper;  b.  Failing to properly inspect the Sleeper to assure that all parts were fit for  their intended purpose;  c.  Acting in a careless and negligent manner:  d.  Failing to promulgate, implement, and enforce proper rules and  regulations to ensure the safe manufacture and distribution of the Sleeper,  which would have prevented the injuries;  e.  Failing to take appropriate action to avoid or mitigate the defect;  f.  Negligently implementing policies and procedures to safely manufacture  and distribute the Sleeper;  g.  Failing to ensure that the Sleeper was free from defects and/or in proper  working order;  h.  Failing to timely warn;  i.  Failing to provide appropriate instructions;  j.  Acting in a manner that justifies imposition of punitive damages; and  k.  Such other acts and omissions as will be shown at the trial of this matter.   47.  The consideration of common questions of fact and law will conserve judicial  resources and promote a fair and consistent resolution of these claims.  9   48.  The injuries to Plaintiffs and the Class Members were also caused by or  aggravated by the fact that Defendants failed to take necessary actions to mitigate the danger of  the mold.   49.  Furthermore, the injuries would not have occurred had the Defendants exercised a  high degree of care. Plaintiffs, therefore, plead the doctrine of res ipsa loquitur.   50.  Plaintiffs and the Class Members are entitled to a judgment finding Defendants  liable to Plaintiffs and the Class Members for damages suffered as a result of Defendants’ acts  and omissions.  51.  Plaintiffs, on behalf of themselves and the Class Members, reallege each and  every allegation set forth above.   52.  Defendants owed a duty to all Plaintiffs and Class Members to exercise  reasonable care in the manufacture and distribution of the Sleeper.   53.  Defendants had a heightened duty of care to all Plaintiffs and the Class Members  because of the great danger associated with manufacturing items for infants.   54.  Defendants breached their legal duty to Plaintiffs and the Class, failed to exercise  reasonable care, and acted with reckless, willful, and wanton disregard for the property and  economic interests of others, including Plaintiffs and the Class Members, in the negligent  manufacture and distribution of the Sleeper.   55.  Defendants knew or should have known that their wanton or reckless conduct  would foreseeably result in defects in the Sleeper, causing injuries to the Plaintiffs and Class  Members.  10   56.  As a direct and proximate result of Defendants wanton or reckless conduct,  Plaintiffs and Class Members have suffered legal injury and damages, in an amount to be proven  at trial.   57.  Defendants’ wanton or reckless conduct, as described herein, entitles Plaintiffs  and Class Members to punitive damages.  58.  Plaintiffs, on behalf of themselves and the Class Members, reallege each and  every allegation set forth above.   59.  Defendants’ conduct with regard to the manufacture and distribution of the  Sleeper is governed by numerous state and federal laws, and permits issued under the authority  of these laws.   60.  These laws and permits create statutory standards that are intended to protect and  benefit Plaintiffs and the Class Members.   61.  Defendants’ violations of these statutory standards constitute negligence per se  under Alabama law.   62.  Defendants’ violations of these statutory standards proximately caused Plaintiffs’  and the Class Members’ injuries, warranting compensatory and punitive damages.  Negligence Per Se.   Negligence.   Wantonness.  