1. Past and future loss of earnings;  1. Providing a product that was unreasonably dangerous in construction or composition;  2. Past and future medical expenses;  2. Providing a product that was unreasonably dangerous in design;  3. Nursing and rehabilitative care expenses;  3. Providing a product that was unreasonably dangerous because of inadequate warning about the product;  30. Defendants are by operation of law presumed to know that their products contained redhibitory defects which they failed to declare, so that defendants are further liable unto Plaintiffs under Articles 2520 et seq. of the Louisiana Civil Code. Such liability includes return of the purchase price, damages, including, but not limited to, mental anguish, and attorney’s fees pursuant to Article 2545 of the Louisiana Civil Code and the presumption contained therein.   31. Separate and apart from, and in the alternative to, their status as manufacturers of their products, defendants entered into a contract of sales with Plaintiff as a result of Plaintiff’s purchase of their products. 32. Defendants are liable unto Plaintiff under the Louisiana Products Liability Act, R.S. 9:2800.51, et seq., as Plaintiff’s damages were proximately caused by the acts and/or omissions of defendants in the following particulars:  32. As a result of their breach of conventional obligations, defendants are obligors in bad faith per Articles 1994 and 1997 of the Louisiana Civil Code and liable unto Plaintiffs for all damages, foreseeable or not, that are a direct consequence of defendants’ failure to perform, including, but not limited to, damages for pecuniary and non-pecuniary loss. 33. Defendants, in the alternative, are liable unto Plaintiff under Article 2298 of the Louisiana Civil Code in that defendants were unjustly enriched without cause at the expense of the Plaintiff. 34. Defendants have engaged in unfair or deceptive acts in violation of the Louisiana Unfair Trade Practices Act, LSA-R..S. 51:1401 et seq., warranting the imposition of damages and attorneys’ fees. 35. To the extent that the evidence establishes that defendants have engaged in intentional misrepresentations, delictual fraud or have violated Art. 1953of the Louisiana Civil Code, Defendants are liable unto Plaintiff for the imposition of damages and attorneys’ fees. 37. Defendants are liable unto Plaintiff for negligent infliction of emotional distress.  38. As the proximate result of the aforementioned acts and/or omissions of defendants, Plaintiff has sustained, or are certain to sustain, the following damages:  39. Plaintiff pleads the doctrine of res ipsa loquitur.   4. Providing a product that was unreasonably dangerous because of nonconformity to express warranties.  4. Loss of earning capacity;  41. Defendants are liable as solidary obligors under Article 1800 and 2324(A) of the Louisiana Civil Code.  42. The Complaint is filed within one (1) year of when Plaintiff first learned of a defect in defendants’ products and the causal link between her injury and a defect in defendants’ products. Plaintiff asserts the doctrine of contra non valentem.  43. Plaintiff requests and is entitled to trial by jury on all issues against all defendants. 5. Past and future pain and suffering;  6. Past and future mental anguish;  7. Fear of future injury;  8. Permanent disability;  9. Loss of enjoyment of life. 