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Ill. Pattern Jury Instr. (Civil) 600.09

Issues--Contribution Following Settlement

activein force · 2026-08-19 – presentas-observed

[1] has paid a sum of money to in settlement of 's claim for his [injuries]

[and] [damages].

of that sum paid.

now claims that he is entitled to contribution from for a percentage

[2] [

liability to

further cla ims that the payment was made in reasonable antic ipation of his

.]

[3] claims that was negligent in one or more of the following respects:

[Set forth in simple form, without undue emphasis, those allegations as to the conduct of

the defendant which are set forth in the complaint for contribution which hav e not been

withdrawn or ruled out by the court and are supported by the evidence.]

[4] further claims that one or more of the foregoing was a proximate cause of 's

[injuries] [and] [damages].

[5] [denies that the payment was made in reasonable antic ipation of liability;]

[denies that he did a ny of the things claimed by ;] [denies that he was neg ligent (in doing

any of the things claimed by

was a proximate cause of

);] [and denies that any claimed act or omission on the part of

's (injuries) (and) (damages)].

[6] [also asserts the following affirmative defense(s):

(Set forth in simple form, without undue emphasis or repetition, those affirmative

defenses in the defendant's answer which have not been withdrawn or ruled out by the court and

are supported by the evidence.)]

[7] [denies (that) (those) affirmative defense(s).]

[8] [(also) claims that was negligent in one or more of the following respects:

(Set forth in simple form, without undue emphasis, those allegations as to the conduct of

the plaintiff which have been set forth in the defendant's answer which have not been withdrawn

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

[9] [further claims that one or more of the fore going was (a) (the) proximate cause

of ' s (injuries) (and) (damages).]

[10] [(admits) (denies)

(Set forth in simple form, without undue emphasis, the admissions, if any, and denials

contained in plaintiff's reply to defendant's allegations.)]

Notes and Comment revised January 2010.

Provenance

Source
illinoiscourts.gov
Retrieved
2026-08-20
Edition
2026-08-19
Content hash
cdc3d3babdd0d463b996440c9163a8b732a1455fe4b071fff19237b3b0b4e4da
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