Conn. Civ. Jury Instr. 4.2-1

[<If dispute is about existence of terms:> The parties have a dispute as to whether the contract

provides for <insert terms in dispute>. The plaintiff claims <insert plaintiff's contention>, and

the defendant claims <insert defendant's contention>. The plaintiff must prove by a

preponderance of the evidence that the contract contained the terms that the plaintiff seeks to

enforce.]

[<If there is a dispute over meaning:> The parties have a dispute as to the meaning of the

language of the contract that states <insert terms in dispute>. Here, the plaintiff claims that this

term means <insert plaintiff's contention> and the defendant claims <insert defendant's

contention>. The plaintiff must prove by a preponderance of the evidence that the disputed

terms meant <insert plaintiff's contention>.]

To determine whether the contract provided <insert disputed issue>, you must decide whether it

was the parties' intent to provide <insert disputed issue>. The first place to look to find the

parties' intent is the wording that was used in the contract. Words in a contract are to be given

their ordinary meaning [, unless they are special terms of trade or the parties have given them

special meaning]. If you cannot determine what was intended from the language you may

consider the circumstances surrounding the entering into the contract or other legal doctrines that

I will provide to you in these instructions.