Ill. Pattern Jury Instr. (Civil) 500.08

Following Settlement--All Causes of Action

[1] [Name of third par ty plaintiff] claims that he is entitled to indemnity from [name of

third party defendant] for a sum of money he, [name of third party plaintiff], has paid to [name of

injured party].

[2] [Na me of third par ty pl aintiff] cla ims that the payment was made in reasonable

anticipation of his liability to [name of injured party].

[3] [Set for th those portions of the IP I issu es instruction which are appropria te to the

indemnitee's allegation(s) that the indemnitor was a tortfeasor who injured the prime plaintiff.]

[4] [Name of third par ty plaintiff] further claims that he is entitled to indemnity because

his liability was the result of his pa ssive conduct and [na me of third par ty defendant]'s conduc t

was active in causing the damages to [name of injured party].

[5] [Na me of third par ty d efendant] [denies that the payment was made in reasonable

anticipation of liability];

[Set forth indemnitor's denial that he did the things charged, that his conduct was

tortious and that that conduct proximately caused injury to the plaintiff.]

[[Name of third par ty defendant] denies that his conduct was active in causing [name of

injured party]'s damages]; [and]

[[Name of third par ty defendant] denies that [name of third par ty plaintiff]'s liability was

passive in causing [name of injured party]'s damages].

[6] [Name of third party defendant] also asserts the following affirmative defense[s]:

[Set forth in simple form without undue emphasis or repe tition those affirmative defenses

in the answer which have not been withdrawn or ruled out by the court and are supported

by the evidence.]

[7] [Name of third party plaintiff] denies [that] [those] affirmative defense[s].