500.05. Issues Made by Pleadings-All Causes of Action-Separate or 3rd Party Implied Indemnity Tried Separately to Different Jury

500.05 Issues Made by the Pleadings--All Causes of Action--Separate or Third Party Complaint for Implied (Active-Passive) Indemnity Tried Separately to Different Jury [1] A judgment has been entered requiring [name of third party plaintiff] to pay a sum of money to [name of plaintiff]. [Name of third party plaintiff] now seeks indemnity for that sum from [name of third party defendant]. [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 he is entitled to indemnity because his liability was the result of his passive conduct and [name of third party defendant]'s conduct was active in causing the [injuries] [damages] to [name of plaintiff]. [4] [Name of third party defendant] [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 defendant] denies that his conduct was active in causing [name of plaintiff]'s [injuries] [damages]]; [[Name of third party defendant] denies that [name of third party plaintiff]'s liability was passive in causing [name of plaintiff]'s [injuries] [damages]]. [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form without undue emphasis or repetition those affirmative defenses in the third party answer which have not been withdrawn or ruled out by the court and are supported by the evidence.]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].