Ill. Pattern Jury Instr. (Civil) 20.01

[1] The plaintiff claims that he was injured and sustained damage, and that the

defendant[s] [was] [were] negligent in one or more of the following respects:

[Set forth in simple form without undue emphasis or repetition

those allegations of the complaint as to the negligence of the

defendants which have not been withdrawn or ruled out by the

court and are supported by the evidence. If there is more than one

defendant and the allegations of negligence are different as

between them, use a form such as:

“Defendant C, in [e.g., failing to keep a proper lookout.”

“Defendant D, in .”]

[2] The plaintiff further claims that one or more of the foregoing was a proximate cause

of his injuries.

[3] The defendant [Defendant C] [denies that he did any of the things claimed by the

plaintiff,] denies that he was negligent [in doing any of the things claimed by the plaintiff] [and

denies that any claimed act or omission on the part of the defendant was a proximate cause of the

plaintiff's claimed injuries].

[4] The defendant[s] claim[s] that the plaintiff was contributorily negligent [in one or

more of the following respects:]

[Set forth in simple form without undue emphasis or repetition

those allegations of the answer as to the plaintiff's

contributory negligence which have not been withdrawn or

ruled out by the court and are supported by the evidence.]

[5] The defendant[s] further claim[s] that one or more of the foregoing was [a] [the]

proximate cause of the plaintiff's injuries.

[6] The plaintiff [denies that he did any of the things claimed by defendant(s),] denies

that he was negligent [in doing any of the things claimed by defendant(s),] [to the extent claimed

by defendant(s),] [and denies that any claimed act or omission on his part was a proximate cause

of his claimed injuries].

[7] The defendant [Defendant C] also sets up the following affirmative defense[s]:

Defendant [Defendant C] claims

[here set forth in simple form without undue emphasis or

repetition those affirmative defenses (except contributory

negligence) in the answer which have not been withdrawn or

ruled out by the court and are supported by the evidence].

[8] The plaintiff denies that [summarize affirmative defense[s]].

[9] The defendant[s] further den[ies] [y] that the plaintiff was injured or sustained

damages [to the extent claimed].

Instruction [5] revised August 2023. Comment revised February 2026.