Three men were riding in a pickup truck when the tire tread separated on a rear wheel. The driver lost control of the truck, which rolled over. The two passengers in the truck were killed, and the estate of one of the passengers brought suit against Cooper Tire, the manufacturer of the tire. The plaintiff argued that the tire was defective in design and had a manufacturing defect. During the discovery portion of the case, the plaintiff sought information regarding all tires manufactured by the defendant; specifically, the plaintiff was seeking information to show that Cooper Tire had notice of a tread separation problem in its other tires. Cooper Tire refused to produce that information, arguing that information regarding other tires that it manufactured but were not at issue in the case was irrelevant. What arguments, if any, could the plaintiff use to establish that the information regarding other tires is relevant? [Mario Alvarez v. Cooper Tire & Rubber Co.,75 So. 3d 789 (Fla. Dist. Ct. App., 4th Dist. 2011).]