UJI 13-302E. Statement of other contentions and denials, causation and burden of proof.

Related to the above, __________________ say(s) and [has] [have] the burden of proving that: ____________________________. (NOTE: List by number each claimed act [and] [or] omission, condition, etc., referenced to specific defendant(s) which is supported by substantial evidence on all other incidental issues such as agency, punitive damages, e.g., 1. Defendant(s)’ misconduct shows an utter indifference to, or conscious disregard for, the safety of others; and punitive damages should be awarded. 2. Defendant __________________ was acting within the scope of Defendant’s employment with defendant __________________). [This] [These] contention(s) [is] [are] denied. [Also, __________________ say(s) and [has] [have] the burden of proving that: __________________. [This] [These] [is] [are] denied.]