CJI-Civ. 9:29A

You are instructed to answer the following questions. You must all agree on your

answers to each question for which an answer is required:

1. Did the plaintiff, (name), have (injuries) (damages) (losses)?

2. Was the defendant, (name of first or only defendant), (negligent) (or) (at fault)?

3. Was the (negligence) (or) (fault), if any, of the defendant, (name of first or only

defendant), a cause of any of the (injuries) (damages) (losses) claimed by the plaintiff?

(4. Was the defendant, [name of second defendant], [negligent] [or] [at fault]?)

(5. Was the [negligence] [or] [fault], if any, of the defendant, [name of second

defendant], a cause of any of the [injuries] [damages] [losses] claimed by the plaintiff?)

If you find that the plaintiff, (name), did not have (injuries) (damages) (losses), or if

you find that (the defendant was not) (none of the defendants was) (negligent) (or) (at fault)

or that no (negligence) (or) (fault) (of the defendant) (of any of the defendants) was a cause

of any of the plaintiff’s claimed (injuries) (damages) (losses), then your foreperson shall

complete only Special Verdict Form A and all jurors shall sign it.

On the other hand, if you find that the plaintiff did have (injuries) (damages)

(losses) and you further find that (the defendant) (one or more of the defendants) was

(negligent) (or) (at fault) and that such (negligence) (or) (fault) was a cause of any of the

plaintiff’s (injuries) (damages) (losses), then on Special Verdict Form B you shall answer

the following questions, and your foreperson shall complete only Special Verdict Form B,

and all jurors shall sign it.

6. Was (name or other appropriate description of designated nonparty) (negligent) (or)

(at fault)?

7. Was the (negligence) (or) (fault), if any, of (name or other appropriate description of

designated nonparty) a cause of any of the (injuries) (damages) (losses) claimed by the

plaintiff?

8. State your answers to the questions as they appear on Special Verdict Form B

relating to the plaintiff’s damages that were caused by the (negligence) (or) (fault) of the

(defendant) (one or more of the defendants) and the (negligence) (or) (fault), if any, of the

nonparty, (name or other appropriate description).

9. Taking as 100 percent the combined (negligence) (or) (fault) of the (defendant)

(defendants) and (any nonparty) you find were (negligent) (or) (at fault) and whose

(negligence) (or) (fault) was a cause of any of the plaintiff’s (injuries) (damages) (losses),

what percentage of (negligence) (or) (fault), if any, was that of the defendant, (name of first

or only defendant), (of the defendant, [name of second defendant],) and of the nonparty,

(name or other appropriate description)?

You must enter the figure of zero, “0,” for the nonparty (and any defendant) you

decide was not (negligent) (or) (at fault) or whose (negligence) (or) (fault) you decide was

not a cause of any of the plaintiff’s (injuries) (damages) (losses).