700.01. Breach of Contract-Terms of Contract Not in Dispute

700.01 Breach of Contract--Terms of Contract Not in Dispute Plaintiff [name of plaintiff] claims [name of defendant] [names of defendants] breached a contract between them. The terms of that contract are as follows: [Describe the contract.] [Name of plaintiff] has the burden of proving [name of defendant] [names of defendants] breached the contract in the following way: [State here the plaintiff's contract claims.] [Name of defendant] [Names of defendants] [deny/denies] [he/she/they] breached the contract[.] [and] [claim[s] and [has/have] the burden of proving [he/she/they] did not have to perform under the contract because [he/she/they] [has/have] the following affirmative defense[s] which excuse[s] performance: [Identify here the affirmative defense(s)]] [Name of plaintiff] denies [name of defendant] [names of defendants]'s affirmative defense[s]. Affirmative defense will be explained in further detail in the following instructions.