CJI-Civ. 2:2

(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.

Each party to this action claims to be entitled to damages from the other. 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, the defendant claims (describe briefly the defendant’s affirmative defense[s]).

As a counterclaim against the plaintiff, the defendant further claims: (state the

essential elements of the counterclaim).

As to the counterclaim, the plaintiff admits (describe briefly the admitted facts, if any).

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

an affirmative defense, the plaintiff claims (describe briefly the plaintiff’s affirmative

defense[s]).

These are the issues you are to decide.