500.06. Issues Made by Pleadings-All Causes of Action-Indemnitee Indemnitor Tortfeasors-Implied Indemnity Tried by Same Jury

500.06 Issues Made by the Pleadings--All Causes of Action--Indemnitee and Indemnitor Are Both Named and Charged as Tortfeasors in Prime Complaint-- Complaint and Third Party Complaint for Implied (Active-Passive) Indemnity Tried Consecutively to Same Jury [1] You have returned a verdict requiring [name of counterplaintiff] to pay a sum of money to [name of plaintiff]. [Name of counterplaintiff] now seeks indemnity for that sum from [name of counterdefendant]. [2] [Name of counterplaintiff] claims that he is entitled to indemnity because his liability was the result of his passive conduct and [name of counterdefendant]'s conduct was active in causing the [injuries] [damages] to [name of plaintiff] in one or more of the following respects: [Set forth in simple form without undue emphasis or repetition those allegations of the counterclaim as to the conduct of the counter defendant which have not been withdrawn or ruled out by the court and are supported by the evidence.] [3] [Name of counterdefendant] [denies that he did any of the things claimed by [name of counterplaintiff]]; [denies that his conduct was active in causing [name of plaintiff]'s [injuries] [damages]]; [denies that [name of counterplaintiff]'s liability was passive in causing [name of plaintiff]'s [injuries] [damages]]. [4] [Name of counterdefendant] also asserts the following affirmative defense[s]: [Set forth in simple form without undue emphasis or repetition those affirmative defenses in the answer to counterclaim which have not been withdrawn or ruled out by the court and are supported by the evidence.] [5] [Name of counterplaintiff] denies [that] [those] affirmative defense[s].