500.08. Issues Made by Pleadings-Complaint for Implied (Active-Passive) Indemnity Following Settlement-All Causes of Action

500.08 Issues Made by the Pleadings--Complaint for Implied (Active-Passive) Indemnity Following Settlement--All Causes of Action [1] [Name of third party plaintiff] claims that he is entitled to indemnity from [name of third party defendant] for a sum of money he, [name of third party plaintiff], has paid to [name of injured party]. [2] [Name of third party plaintiff] claims that the payment was made in reasonable anticipation of his liability to [name of injured party]. [3] [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.] [4] [Name of third party plaintiff] further 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 damages to [name of injured party] . [5] [Name of third party defendant] [denies that the payment was made in reasonable anticipation of liability]; [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 injured party]'s damages]; [and] [[Name of third party defendant] denies that [name of third party plaintiff]'s liability was passive in causing [name of injured party]'s damages]. [6] [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forth in simple form without undue emphasis or repetition those affirmative defenses in the answer which have not been withdrawn or ruled out by the court and are supported by the evidence.] [7] [Name of third party plaintiff] denies [that] [those] affirmative defense[s].