600.09. Issues-Contribution Following Settlement

600.09 Issues--Contribution Following Settlement [1] [_________________] has paid a sum of money to [_________________] in settlement of [_______________]'s claim for his [injuries] [and] [damages]. [______________] now claims that he is entitled to contribution from [______________] for a percentage of that sum paid. [2] [[______________] further claims that the payment was made in reasonable anticipation of his liability to [______________].] [3] [______________] claims that [______________] was negligent in one or more of the following respects: [Set forth in simple form, without undue emphasis, those allegations as to the conduct of the defendant which are set forth in the complaint for contribution which have not been withdrawn or ruled out by the court and are supported by the evidence.] [4] [________________] further claims that one or more of the foregoing was a proximate cause of [________________]'s [injuries] [and] [damages]. [5] [______________] [denies that the payment was made in reasonable anticipation of liability;] [denies that he did any of the things claimed by [______________];] [denies that he was negligent [in doing any of the things claimed by [______________]];] [and denies that any claimed act or omission on the part of [______________] was a proximate cause of [______________]'s [injuries] [and] [damages]]. [6] [[______________] also asserts the following affirmative defense[s]: [Set forth in simple form, without undue emphasis or repetition, those affirmative defenses in the defendant's answer which have not been withdrawn or ruled out by the court and are supported by the evidence.]] [7] [[______________] denies [that] [those] affirmative defense[s].] [8] [[______________] [also] claims that [______________] was negligent in one or more of the following respects: [Set forth in simple form, without undue emphasis, those allegations as to the conduct of the plaintiff which have been set forth in the defendant's answer which have not been withdrawn or ruled out by the court and are supported by the evidence.]] [9] [[______________] further claims that one or more of the foregoing was [a] [the] proximate cause of [______________]'s [injuries] [and] [damages].] [10] [[________________] [admits] [denies] [Set forth in simple form, without undue emphasis, the admissions, if any, and denials contained in plaintiff's reply to defendant's allegations.]]