CJI-Civ. 2:1

(The Court) (I) will now explain the claims and defenses of each party to the case

and the law governing the case. Please pay close attention to these instructions. These

instructions include both general instructions and instructions specific to the claims and

defenses in this case. You must consider all the general and specific instructions together.

You must all agree on your verdict, applying the law (, as you are now instructed,) to the

facts as you find them to be.

The parties to this case are: (name), the plaintiff and (name), the defendant.

The plaintiff claims: (state the essential elements of the claim using simple language

based on the pleadings, evidence and the pretrial order and avoiding use of technical terms and

words such as “allege” or “contend.” Each statement should include reference to time, place

and circumstances).

The defendant admits (describe briefly the admitted facts, if any). The defendant

denies (describe briefly the defendant’s position regarding plaintiff’s claims). As (an)

affirmative defense(s), the defendant claims (describe briefly the defendant’s affirmative

defense[s]).

These are the issues you are to decide.