190.02 Nursing Home Care Act-Issues Made by the Pleadings-No Issue as to Agency

190.02 Nursing Home Care Act--Issues Made by the Pleadings--No Issue as to Agency [1] [2] [3] [The plaintiff claims that the defendant[s] [was] [were] the [licensee] [and] [or] [owner] of [name of facility]]. [The plaintiff claims that [name of resident] was a resident of [name of facility]]. The plaintiff claims that [name of resident] was injured and sustained damage and that the defendant[s] violated the Nursing Home Care Act in that: A. B. [The defendant negligently] [The defendant intelligently] [Set forth in simple form without undue emphasis or repetition those allegations of the complaint asserting abuse or neglect under the Act or violations of federal or state regulations that have not been withdrawn or ruled out by the court and are supported by the evidence.] [4] [5] The plaintiff further claims that one or more of the foregoing was a proximate cause of [name of resident]'s injuries. The defendant[s] [denies] [deny] [that [it] [they] violated the Nursing Home Care Act] [and] [that [it] [they] [was] [were] an [owner] [licensee] of a facility covered under this Act] [and] [that [name of resident] was a resident of [name of facility]]. The defendant[s] [denies] [deny] that any claimed act or omission on the defendant's part was a proximate cause of [name of resident]'s claimed injuries. [The defendant[s] further [denies] [deny] that [name of resident] [was injured] [or] sustained damages [to the extent claimed].] [The defendant[s] further [claims] [claim] that [name of resident] [was contributorily negligent in one or more of the following respects.] [Set forth in simple form without undue emphasis or repetition those allegations of the answer as to the plaintiff's contributory negligence that have not been withdrawn or ruled out by the court and are supported by the evidence.] [9] [The defendant[s] further claim[s] that one or more of the foregoing was [a] [the sole] proximate cause of the [name of resident] injuries.] [6] [7] [8] [10] [The plaintiff [denies that [name of resident] did any of the things claimed by defendant] [denies [name of resident] was negligent in doing any of the things claimed by the defendant to the extent claimed by the defendant] [and denies that any claimed act or omission on [name of resident]'s part was a proximate cause of [name of resident]'s claimed injuries].]