500.07. Issues Made by Pleadings-All Causes of Action-Indemnitor Not Tortfeasor-Sep. or 3rd Party Implied Indemnity-Same Jury

500.07 Issues Made by the Pleadings--All Causes of Action--Indemnitor Not Charged as a Tortfeasor in Prime Complaint--Separate or Third Party Complaint for Implied (Active-Passive) Indemnity--Tried Consecutively to Same Jury [1] You have returned a verdict requiring [name of defendant] to pay a sum of money to [name of plaintiff]. [Name of third party or counterplaintiff] now seeks indemnity for that sum from [name of third party or counterdefendant]. [2] [Set forth those portions of the IPI issues instructions which support the indemnitee's allegation[s] that the indemnitor was a tortfeasor who injured the prime plaintiff.] [3] [Name of third party or counterplaintiff] claims that he is entitled to indemnity because his liability was the result of his passive conduct and [name of third party or counterdefendant]'s conduct was active in causing the [injuries] [damages] to [name of plaintiff]. [4] [Name of third party or counterdefendant] [Set forth indemnitor's denial that he did the things charged, that his conduct was tortious and that that conduct proximately caused injury to the plaintiff.] [[Name of third party or counterdefendant] denies that his conduct was active in causing [name of plaintiff]'s [injuries] [damages]]. [[Name of third party or counterdefendant] denies that [name of third party or counterplaintiff]'s liability was passive in causing [name of plaintiff]'s [injuries] [damages]]. [5] [Name of third party or counterdefendant] also asserts the following affirmative defense[s]: [Set forth in simple form without undue emphasis or repetition those affirmative defenses in the indemnitor's answer which have not been withdrawn or ruled out by the court and are supported by the evidence.] [6] [Name of third party or counterplaintiff] denies [that] [those] affirmative defense[s].