UJI 13-302C NMRA
UJI 13-302C. Statement of denial and affirmative defense(s).
The defendant(s) deny(ies) what the plaintiff(s) ] say(s) about
________________________ (theory of recovery(ies) by name)] [and defendant(s)
say(s) that: ____________________________________________________________
______________________________________________________________________
(Violation of the ordinance was excused or justified, [and]
The plaintiff(s) [was] [were] negligent, [and]
Another party was negligent, [and]
A non-party was negligent, [and]
Etc.).