105.07.02. Informed Consent-Issues Made by the Pleadings-Professional Negligence-One Plaintiff and One Defendant

105.07.02 Informed Consent--Issues Made by the Pleadings--Professional Negligence--One Plaintiff and One Defendant [The plaintiff's complaint consists of [___] counts. The issues to be decided by you under Count [___] of the complaint are as follows:] The plaintiff claims that the defendant failed to inform the plaintiff of those [risks of] [and] [or] [alternatives to] the [describe the procedure performed] which a reasonably well-qualified [insert appropriate medical professional] would have disclosed under the same or similar circumstances; The plaintiff further claims that if the defendant had disclosed those [risks] [and] [or] [alternatives], a reasonable person in the plaintiff's position would not have submitted to the [describe the procedure performed]; and The plaintiff further claims that he was injured, and that the defendant's failure to disclose those [risks] [and] [or] [alternatives] was a proximate cause of that injury. The defendant [denies that he failed to inform the plaintiff of those [risks of] [and] [or] [alternatives to] the [describe the procedure performed] which a reasonably wellqualified [insert appropriate medical professional] would have disclosed under the same or similar circumstances;] [denies that a reasonable person in the plaintiff's position would not have submitted to the [describe the procedure performed] after being told of those [risks] [and] [or] [alternatives]]; [denies that the plaintiff was injured or sustained damages [to the extent claimed];] [and] [denies that any failure to disclose those [risks] [and] [or] [alternatives] was a proximate cause of any injury].