401.24 COUNTERCLAIMS, CROSS CLAIMS, AND THIRD PARTY CLAIMS
NOTE ON USE FOR 401.24
Generally counterclaims, cross claims, and third party claims should follow the same pattern of issues, applicable rules, burden of proof, and defenses as on the main claim. For an example of how a counterclaim can be integrated into an instruction, see Model Instruction No. 4.
401.19 ISSUES ON PLAINTIFF’S CLAIM — COMMON CARRIER The [next] issues on (claimant’s) claim, for you to decide are: whether (defendant) in (describe conduct) failed to exercise the highest degree of
401.18 ISSUES ON PLAINTIFF’S CLAIM — GENERAL NEGLIGENCE The [next] issues you must decide on (claimant’s) claim against (defendant) are: a. Negligence, generally: whether (defendant) was negligent in
401.17 BURDEN OF PROOF ON PRELIMINARY ISSUES If the greater weight of the evidence does not support (claimant’s) claim on [this issue] [these issues], that (describe preliminary issue), then your verd
