500.04. Issues Made by Pleadings-All Causes of Action-Indemnitor Not Complaint Tortfeasor-Implied Indemnity Tried Concurrently

500.04 Issues Made by the Pleadings--All Causes of Action--Indemnitor Is Not Charged as a Tortfeasor in Prime Complaint--Complaint and Claim for Implied (Active-Passive) Indemnity--Tried Concurrently [1] In addition to the claim[s] of [name of plaintiff] against [name of defendant] in this case, [name of third party plaintiff] claims he is entitled to indemnity from [name of third party defendant] for any sum [name of third party plaintiff] may become liable to pay [name of plaintiff]. [2] [Set forth those portions of the IPI issues instruction which are appropriate to the indemnitee's allegation(s) that the indemnitor was a tortfeasor who injured the prime plaintiff.] [3] [Name of third party plaintiff] claims that if he is found liable to [name of plaintiff], he, [name of third party plaintiff], is entitled to indemnity because his liability, if any, was the result of his passive conduct and [name of third party defendant]'s conduct was active in causing the [injury] [damages] to [name of plaintiff]. [4] [Name of third party defendant] [Set forth the 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 defendant] denies that his conduct was active in causing [name of plaintiff]'s [injury] [damage]]. [[Name of third party defendant] denies that [name of third party plaintiff]'s conduct was passive in causing [name of plaintiff]'s [injury] [damage]]. [5] [Name of third party defendant] also asserts the following affirmative defense[s]: [Set forth in simple form without undue emphasis or repetition those affirmative defense(s) in that third party answer which have not been withdrawn or ruled out by the court and are supported by the evidence.] [6] [Name of third party plaintiff] denies [that] [those] affirmative defense[s].