Manly’s defence against Lloyd Perrett’s $5m claim
The Sea Eagles’ claim of “contributory negligence” by Lloyd Perrett
i. Failing to sufficiently manage his health, weight and diet in the off-season ahead of the training session;
ii. Failing to properly train in the off-season and prepare to participate in the training session;
iii. Failing to properly monitor his health, fitness and ability to participate in the training session;
iv. Failing to sufficiently hydrate himself before and during the training session;
v. Failing to communicate his condition/fitness to coaching staff at the training session;
vi. Before and during the third time trial, failing to identify that he should stop for a break;
vii. Not bringing his own water bottle to the training session;
viii. Putting himself in a position of danger;
ix. Failing to take any or any reasonable care for his safety;
x. Failing to exercise caution;
xi. Failing to take any or any proper precautions for his own safety in the circumstances; and
xii. Failing to detect, observe and take heed of an obvious risk (the presence of which is not admitted).