Trust Invs., N.A. (3) The fact of such a release or covenant not to sue, or that any defendant has been dismissed by order of the court shall not be made known to the jury. Our West Palm Beach business litigation attorneys are here to expand on the subject of affirmative defenses to a breach of contract claim. However, in order for it to apply in any context, four elements must be present: The first element should be obvious. The Florida Second District Court of Appeals' recent decision in Fiberglass Coatings v. Interstate Chemical, Inc., Case No. 2d 880, 882 (Fla. 4th DCA 2005) ("[A] material breach of the agreement allows the . Often a plaintiff is required to make the claim within a specific time after . In those circumstances, common law contract principles may provide a defense to claims of contractual breach caused by the COVID-19 pandemic. Most of the time, it is pled as an affirmative defense incorrectly. Fraud. For instance, say a plaintiff sues three defendants in negligence for the same damage. See Taylor v. Genesee & Wyoming, Inc., 2015 WL 12683821 *5 (M.D. Defending against breach of contract claims requires a meticulous review of your situation and a full exploration of your options and available defenses. An affirmative defense is one of the most common types of defenses against a breach-of-contract claim. This is a strong defense as the person or entity forfeits its consensual partnership in the contract. ), Equitable Relief: One seeking Equity MUST do Equity, Exculpatory Clauses will be Strictly Construed to Determine Enforceability, Do Yourself a Favor: Get a Court Reporter at that Impactful Hearing, Real Estate Brokers are NOT Immune from Liability, Res Judicata and 4 Requirements that Must be Demonstrated, Writ of Prohibition to Prevent Trial Court from Exceeding Jurisdiction, Directed Verdict Granted where No View of Evidence Could Support Jury Verdict, Petition for Writ of Mandamus Directing Trial Court to Take Action, Considerations: Independent Tort Doctrine and Claim Known as Equitable Accounting, Waiver is a Voluntary Relinquishment of a Known Right that Must be Proven with a Clear Showing, Dismissal Without Prejudice does NOT Trigger Attorneys Fees under Proposal for Settlements, Bert Harris Act and Competing Motions for Summary Judgment, Plaintiff MUST Confer Direct Benefit on Defendant to Prove Unjust Enrichment, You Cannot Intentionally Render Moot a Plaintiffs Lawsuit, Apparent Authority of Agent to Bind Principal, Serving the Civil Remedy Notice (CRN) to Perfect a First-Party Bad Faith Insurance Claim, Breach of Express Contract is Exception to Sovereign Immunity, Moving for and Challenging a Protective Order under the Apex Doctrine, Purchase-and-Sale Contract: Your Right to Modify Them, Premise Liability and Duty Owed to Business Invitees, Recovering Attorneys Fees in Litigating the Amount of Attorneys Fees, Business Interruption due to COVID-19 NOT Covered under Commercial Property Insurance Policy, Foreseeability and the Duty Element of a Negligence Claim, Post-Judgment Receiver Appointed to Collect on Behalf of Judgment Creditor, Reminder: Not Every Breach is a Material Breach of Contract, Adding a Non-Party Fabre Defendant to the Verdict Form, 3-Step Process for Objections to Trade Secrets, Attorneys Fees to Prevailing Party Under FDUTPA Claim are PERMISSIVE, Contractually Disclaiming a Fraud Claim (Possible, but not Easy to do), Floridas Single Publication Rule (and Defamation Claims), Reasonable Time to Accept Settlement Offer (is a Question of Fact), Contingency Fee Multiplier Must Establish the Relevant Market Factor, Business Judgment Rule Designed to Shield Directors from Personal Liability, Ambiguity in Insurance Policy Interpreted in Favor of Insured, Pure Bill of Discovery NOT for Purposes of Fishing Expedition, Partition Action does Not Result in Money Damages Against a Party, Consider Prevailing Party Attorneys Fees before Voluntarily Dismissing Case, Confession of Judgment does Not Start the Clock to File Motion for Attorneys Fees, Quick Note: Motion for Protective Order Reviewed Under Abuse of Discretion Standard of Review, There are NO Magic Buzz Words to Effectuate an Assignment, Presuit Appraisal Requirement under Bert J. Harris Act, Determining whether Lis Pendens Against Property is Appropriate Fair Nexus, Recovering Attorneys Fees Incurred on Partys Behalf, To Pierce Corporate Veil, there Needs to be Sufficient Findings of Improper Conduct, Timely Moving for Trial De Novo after Non-Binding Arbitration Award, Attorneys Fees do Not have to be Quantified in Proposal for Settlement, A Bad Deal does NOT Make It an Unlawful Deal, Dismissal of Complaint (Action under Floridas Public Whistleblower Act) for Failure to State Cause of Action, Duty Element of Negligence Did Defendants Conduct Foreseeably Create Broader Zone of Risk, Trier of Fact Determines Weight of the Evidence, Oops! The defenses do not necessarily dispute the plaintiff's primary claim but present the circumstances that should dismiss it. Were changing the way people think about lawyers. Today, a minor is not recognized to possessed full legal capacity to contract. Breach of Implied in Law Contract, Breach: 07. One such affirmative defense is the Statute of Limitations. Breach of Implied Warranty of Fitness for a Particular Purpose, Contribution Uniform Contribution Among Tortfeasors Act, Emotional Distress, Intentional Infliction, Invasion of Privacy Public Disclosure of Private Facts, Tortious Interference: 1. Directors Liabilities and Responsibilities, Joint Ventures and International Business Agreements, Acquisition and Sale of U.S. or Foreign Companies, Fiduciary duties of officers and directors, Litigation, arbitration and risk management, E-2 Visa Requirements, Eligibility and Benefits, EB-1C Multinational Manager and Executive, P-1 Visa Athletes and Entertainment Groups. In an affirmative defense, you do not contest the claims of the plaintiff; however, you do contest that there were additional factors that render the breach of contract claim irrelevant. Accordingly, it is hereby ORDERED AND ADJUDGED: 1. (McCulloch, Debra) Download PDF Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. e.g., the plaintiff owner may be able to state both a cause of action for breach of the contract against the general contractor as well as negligence, which is an action sounding in tort law, for damages unconnected with relief that may have been provided for in the contract . If so, the breach of fiduciary duty claim may be dismissed as duplicative. A set of facts that, if true, entitle an individual or entity to be awarded a remedy by a court of law. It is a hard defense to prevail on because it is akin to fraud: Unclean hands is an equitable defense much like fraud. Business. A Statute of Limitations is a state law that prohibits a plaintiff from winning a lawsuit if they simply wait too long to enforce their rights. Arbitrability of a Dispute Does a Judge or Arbitrator Decide? This doctrine of avoidable consequences defense holds that a plaintiff cannot recover damages caused by a defendant that the plaintiff could have reasonably avoided. Did You Receive a Copyright Infringement Demand Letter. On the other hand, if there was an argument that there were separate theories of liability / claims against the other two defendants and potentially different elements of damages, the plaintiff would want to allocate the settlement consideration in the release agreement to these separate theories of liability / claims to create the argument that set-off is not appropriate. In contract actions, set-off must be raised as an affirmative defense and proven at trial (and determined by the trier of fact) or else the defendant waives the right to assert set-off. Fifth Affirmative Defense 5. Section 600 Substantive Instructions General 11 College, 905 So. v. Domino, 896 So. Gulisano Law, PLLC. Materiality is a question of fact, meaning the issue is decided by e jury (or the judge in a bench trial). Breach of Implied in Fact Contract, Breach: 06. Felgenhauer, 891 So.2d at 1045-46. There Must be a Prior Breach of a Provision in the Contract. 2d 749, 752 (Fla. 4th DCA 2008), the Court found that a commercial lessors failure to obtain an estimate by a contractor or architect, as required by the lease, prior to sending notice of its intent to terminate lease was a technical, rather than a material, breach of a commercial lease agreement. It is asserted, but not really a defense a party can ever prove. An affirmative defense is a defense that essentially provides a reason why you should win even if the plaintiff in a lawsuit can prove its case. PDF. The objective is to prevent the plaintiff from obtaining a windfall by obtaining overlapping compensation for the same damages. A prior breach can also be implicitly waived by the parties conduct. Law firm website design by Rowboat Media LLC. Personal Injury, Divorce & Criminal Lawyers in Stuart, Delray Beach, Boca Raton, Port St Lucie, Stuart Deerfield Beach West Palm Beach Delray Beach Boca Raton, Commercial Litigation By Tim Nies, Esq. . If this is a defense you want to try to prove, remember you will need to factually prove the bad unclean hands conduct and the elements to satisfy the defense. Affirmative defenses are reasons and evidence provided by the defense to show why the plaintiff should not win the case. Delray Beach 33444 COUNT V QUANTUM MERUIT 23. 2d 1202, 1210 (M.D. While it is possible to contract around many of the rules of agreement, performance and liability, the rules discussed in this article are for the most part mandatory, in that the contracting parties do not have the freedom to waive these defenses. Copyright 2023 The Florida Litigation Guide, 1997 to 2022 - Litigation Guide Publishing, LLC |, * Fla. R. Civ. Examples of other potential affirmative defenses are: There are also many other affirmative defenses, depending on the type of case. An affirmative defense is the most common means of defense in a breach of contract case. Fla. Sept. 25, 2015). (The vicariously liable party is responsible to the plaintiff to the same extent as the primary [defendant] actor; both are jointly liable for all of the harm that the primary actor has caused. ), Equitable Relief: One seeking Equity MUST do Equity, Exculpatory Clauses will be Strictly Construed to Determine Enforceability, Do Yourself a Favor: Get a Court Reporter at that Impactful Hearing, Real Estate Brokers are NOT Immune from Liability, Res Judicata and 4 Requirements that Must be Demonstrated, Writ of Prohibition to Prevent Trial Court from Exceeding Jurisdiction, Directed Verdict Granted where No View of Evidence Could Support Jury Verdict, Petition for Writ of Mandamus Directing Trial Court to Take Action, Considerations: Independent Tort Doctrine and Claim Known as Equitable Accounting, Waiver is a Voluntary Relinquishment of a Known Right that Must be Proven with a Clear Showing, Dismissal Without Prejudice does NOT Trigger Attorneys Fees under Proposal for Settlements, Bert Harris Act and Competing Motions for Summary Judgment, Plaintiff MUST Confer Direct Benefit on Defendant to Prove Unjust Enrichment, You Cannot Intentionally Render Moot a Plaintiffs Lawsuit, Apparent Authority of Agent to Bind Principal, Serving the Civil Remedy Notice (CRN) to Perfect a First-Party Bad Faith Insurance Claim, Breach of Express Contract is Exception to Sovereign Immunity, Moving for and Challenging a Protective Order under the Apex Doctrine, Purchase-and-Sale Contract: Your Right to Modify Them, Premise Liability and Duty Owed to Business Invitees, Recovering Attorneys Fees in Litigating the Amount of Attorneys Fees, Business Interruption due to COVID-19 NOT Covered under Commercial Property Insurance Policy, Foreseeability and the Duty Element of a Negligence Claim, Post-Judgment Receiver Appointed to Collect on Behalf of Judgment Creditor, Reminder: Not Every Breach is a Material Breach of Contract, Adding a Non-Party Fabre Defendant to the Verdict Form, 3-Step Process for Objections to Trade Secrets, Attorneys Fees to Prevailing Party Under FDUTPA Claim are PERMISSIVE, Contractually Disclaiming a Fraud Claim (Possible, but not Easy to do), Floridas Single Publication Rule (and Defamation Claims), Reasonable Time to Accept Settlement Offer (is a Question of Fact), Contingency Fee Multiplier Must Establish the Relevant Market Factor, Business Judgment Rule Designed to Shield Directors from Personal Liability, Ambiguity in Insurance Policy Interpreted in Favor of Insured, Pure Bill of Discovery NOT for Purposes of Fishing Expedition, Partition Action does Not Result in Money Damages Against a Party, Consider Prevailing Party Attorneys Fees before Voluntarily Dismissing Case, Confession of Judgment does Not Start the Clock to File Motion for Attorneys Fees, Quick Note: Motion for Protective Order Reviewed Under Abuse of Discretion Standard of Review, There are NO Magic Buzz Words to Effectuate an Assignment, Presuit Appraisal Requirement under Bert J. Harris Act, Determining whether Lis Pendens Against Property is Appropriate Fair Nexus, Recovering Attorneys Fees Incurred on Partys Behalf, To Pierce Corporate Veil, there Needs to be Sufficient Findings of Improper Conduct, Timely Moving for Trial De Novo after Non-Binding Arbitration Award, Attorneys Fees do Not have to be Quantified in Proposal for Settlement, A Bad Deal does NOT Make It an Unlawful Deal, Dismissal of Complaint (Action under Floridas Public Whistleblower Act) for Failure to State Cause of Action, Duty Element of Negligence Did Defendants Conduct Foreseeably Create Broader Zone of Risk, Trier of Fact Determines Weight of the Evidence, Oops! An affirmative defense generally does not deny the mitigating facts or circumstances. In Florida, under Rule 1.110 (d) of the Florida Rules of Civil Procedure, the following affirmative defenses to breach of contact must be raised when pleading to a preceding pleading: accord and satisfaction, arbitration and award, discharge in bankruptcy, duress, estoppel, failure of consideration, fraud, illegality, laches, payment release, res 2d at 738 (emphasis added). Breach Implied Covenant of Good Faith & Fair Dealing, Breach: 10. One such affirmative defense is the Statute of Limitations. In addition, even if a warranty is waived or limited, there are often still claims that may be made if the waivers or limitations are unfair or unreasonable. 2023 Malescu Law P.A. P. 1.110. Copyright 2013 Rudnitsky Law Firm . & Mgmt. For example, in a breach of contract lawsuit, they have to prove the existence of a contract with you (which includes offer, acceptance and valid consideration), that you breached the contract, and that they suffered damages as a result of the breach. the non-breaching party must not have waived the right to enforce the prior breach against the opposing party. For example, the Statute of Limitations for a breach of contract in Florida can be four years. 2d 801, 802 (Fla. 1st DCA 1998) (tender of payment one day late was not a material breach of settlement agreement). Otherwise, the court will consider them waived and you will not be allowed to use these defenses later in the case. The main defenses include: Unilateral or Mutual Mistake; Misrepresentation and Fraud; Duress and Undue Influence; Unconscionability; Lack of Consent; Impossibility or Impracticability; Frustration of Purpose; and Statute of Frauds As a general rule, time is considered to be of the essence where an agreement specifies, or where such may be determined from the nature of the subject matter of the contract, or where treating time as nonessential would produce a hardship, or where notice has been given to the defaulting party requiring that the contract be performed within a stated time, which must be a reasonable time according to the circumstances. Sublime, Inc. v. Boardmans Inc., 849 So. But what do you do if the credit card company or other plaintiff can prove its case? Inc., 6 F. Supp. 3d at 1309 (Whether a particular breach is material raises an issue of fact.). in Miami-Dade County, Florida wherein the Defendant hired the Plaintiff as his attorney. That one call can mean the difference between winning and losing your lawsuit. 3d at 1309 (quotation omitted) (emphasis added) (There are few principles of contract law better established, or more uniformly acknowledged, than the rule that when a contract not fully performed on either side is continued in spite of a known excuse, the right to rely upon the known excuse is waived.). The Florida Litigation Guide Provides Everything A Lawyer Needs To Know AboutBreach: 07. However, once the age of majority is reached, the minor, now an adult, can ratify and affirm the contract. Denied. (See also this, Value of Restrictive Covenant when Moving for Permanent Injunction, Reasonable Attorneys Fee Hearing Does Attorney Need to Testify at Hearing, Word to the Wise: File Your Notice of Appeal TIMELY, Contract is Not Hearsay; It has Independent Legal Significance, Voluntarily Dismissing a Lawsuit that Gives Rise to Attorneys Fees (Oh No! While unclean hands may sound like a great affirmative defense in certain contexts, asserting the defense and actually proving and prevailing on it are two different things. See e.g., AVVA-BC, LLC v. Amiel, 25 So. First, releasing the two defendants prior to trial does not operate as a release of the remaining defendant. Fraud in the inducement means that the party was induced or lured into signing the contract through fraud and the provisions of the contract are not in the best interest of the defending party. A cause of action is used synonymously with "theory" or "legal theory." 416.28 AFFIRMATIVE DEFENSE - FRAUD IN THE INDUCEMENT . Copyright 2022.All Rights Reserved. Specifically, TWC contends that Diverse's claim for breach of contract, as to the 2001 Agreement, is barred by novation We're currently offline. Admitted. noun. Romy B. Jurado, Esq. Section 500 Damages Plaintiff and Defendant are parties to a written contract: The contract is ambiguous about the permissibility or scope of the conduct in question; Defendant, through a conscious and deliberate act, fails or refuses to discharge contractual responsibilities that unfairly frustrates the contracts purpose and disappoints the Plaintiffs expectations; Defendants breach deprives the Plaintiff of the contracts benefits; and. Honest, hardworking sellers should not be held hostage to the unreasonable expectations of an overly demanding buyer. If you choose not to raise any of . If they then sue you for the original amount owed before the settlement, you can assert the affirmative defense of Accord and Satisfaction. v. Domino, 896 So. Extra-Contractual Damages cannot be Recovered against Property Insurer Absent Bad Faith Claim, In Ruling on Motion to Compel Arbitration, Trial Court Must Determine whether Parties Bound by Arbitration Provision, Recording Documents in Public Records to put Others on Constructive Notice, Proposals for Settlement and Dismissals WITHOUT PREJUDICE, Just because You Recovered an Affirmative Judgment does NOT Mean you Are the Prevailing Party for Purposes of Attorneys Fees, PLEAD SUFFICIENT ALLEGATIONS SUPPORTING PERSONAL JURISDICTION, Pleading the 5th Amendment Right Against Self Incrimination in a Civil Dispute, Owner can Testify as to the Value of His Property, Piercing the Corporate Veil is NO Easy Feat, 3-Step Process to Determine Production of Document under Trade Secret Privilege, Loss of Future Earning Capacity Damages Must be Proven with Reasonable Degree of Certainty, Declaration Cannot Take Away Common Elements in a Condominium, Properly Alleging a Trade Secret Misappropriation Claim under Florida Law. Instead of proving you didn't break the contract, you fully accept your role in breaking the contract. The basis for the claim is that even if you owe the plaintiff money on its claim, it owes you money on other claims, and your claim can reduce the value of plaintiff's claim. There are three types of warranty of quality: All warranties are capable of being limited or waived, but each requires its own specific process for waiver or limitation to validity. The second element, which requires that the breach be material, bears on the nature and impact of the breach. Preliminary Sections Floridas prior breach doctrine, sometimes referred to as the first breach doctrine, is a fundamental principle of contract law. Breach of Third-Party Beneficiary Contract, Breach: 05. Lets break this down as applied to the above hypothetical. whose benefit the action is brought. Prior to trial, the plaintiff settled with two of the defendants for a total of $100,000 and gave the defendants releases. If you are located in Central Florida (including Seminole County, Orange County, Lake County, Brevard County, Volusia County or Flagler County), we would be honored if you would call us at 386-444-3032 for a free consultation. The waiver of a prior breach claim or defense may be expressed by contract 10 or implied by conduct. See e.g., Indemnity Ins. 3d 7 (Fla. 3d DCA 2009) (reversing rescission of lease premised upon an alleged prior breach of dependent covenant based on waiver by acceptance of benefits under the lease). The failure to meet contractual deadlines may or may not be deemed material. The plaintiff unreasonably delayed seeking the breach of contract suit in court, and; That delay caused prejudice or a harm to the defendant due to that delay. 2023 The Florida Bar. In response, APCO filed its Answer, which included multiple affirmative defenses to Zitting's breach of contract claim. AFFIRMATIVE DEFENSES 26. Click the icon above to call Gulisano Law now for a free consultation. The Affirmative Defenses (Attachment 4) form describes the most common defenses to a breach of contract case. List of Affirmative Defenses: - failure to state a claim upon which relief may be granted (almost always use) - statutory defenses prerequisites (these will vary depending on the claims) - preemption by federal or other law - accord and satisfaction - arbitration and award - assumption of risk - unavoidable accident - economic loss rule It is a hard defense to prevail on because it is akin to fraud: Count I - Breach of Contract The 2001 Agreement [26] TWC raises multiple affirmative defenses, which it argues serve as a bar to Diverse's Claim for breach of the 2001 Agreement. (561) 948-5588, 900 SE Ocean Boulevard Impossibility of performance. The answer is not necessarily, if you can prove a valid affirmative defense. EIGHTH AFFIRMATIVE DEFENSE (Doe/Roe Defendants) 8. Everything You Need to Know About Affidavits An affidavit is a legal written statement, sworn under oath and signed by an affiant recounting the facts surrounding an event or situation. . In the case of duress and undue influence, a party was forced to sign a contract against his or her will. Duress and undue influence. However, the greater weight of authority treats these concepts as distinct elements of the analysis. If someone is forced to enter into a contract by force or threat, there will be no contract as the force or threat deprives that person or entity of the ability to choose. Suite 375 Promissory Estoppel The legal doctrine of promissory estoppel may be raised as an affirmative defense in a breach of contract claim. Section 400 Substantive Instructions Breach of Contract Cases. See Acosta v. Dist. affirmative relief and sue on the basis of any cause of action that may be appropriate in a particular situation. Unlike the Florida state court authority on this issue, there are numerous federal District Court opinions supporting the position that a plaintiff asserting a breach of contract claim and declaratory judgment claim in the same action cannot state a "bona fide need" for the declaratory judgment when the breach of contract claim has not been A prior breach can be expressly waived according to the terms of the contract. The key point, however, is that you can lose your affirmative defenses if you do not assert them properly and at the right time. Value of Restrictive Covenant when Moving for Permanent Injunction, Reasonable Attorneys Fee Hearing Does Attorney Need to Testify at Hearing, Word to the Wise: File Your Notice of Appeal TIMELY, Contract is Not Hearsay; It has Independent Legal Significance, Voluntarily Dismissing a Lawsuit that Gives Rise to Attorneys Fees (Oh No! However, a civil theft claim includes many nuances and high . While materiality is a fact-based analysis focused on the substantiality of the breach, the injury suffered and closely related factors, whether a covenant is dependent is a question of law for the court to decide based on the intent of the parties gleaned from the face of the contract. We want to hear your story, and share ours. With a Dead Body, Tortious Interference: 4. Model Form of Verdict for Affirmative DefenseMutual Mistake of Fact, Form 416.28. These defenses are meant to help the defense side win the case even if the plaintiff's claims of breach of contract are true. 2016) ([T]he general rule is that a material breach of the agreement allows the non-breaching party to treat the breach as a discharge of his contractual liability.); Hamilton v. Suntrust Mortg. Download . Second, the court shall set-off any amount the plaintiff received from the other two defendants in the judgment the plaintiff receives since it involves the same damage, meaning the set-off would reduce the jury verdict and would be embodied in the final judgment. That simply means you reached a new agreement that you fully complied with, and they are not entitled to renege on their deal. A person must have legal capacity to contract, otherwise he or she cannot be bound by a contract. Rule 1.110 - GENERAL RULES OF PLEADING. A contract that violates provisions of the law cannot be enforced in court. "hours worked" under the FLSA. Defendants did not know or show reckless disregard for whether their conduct was prohibited by the FLSA. For many reasons, it is imperative you retain the services of a forceful and thorough advocate who can protect your interests. As Gold says, "There are certainly defenses to breach of contract." There are several ways in which you can defend a lawsuit filed against you by a credit card company, debt collector, bank, auto finance company and other plaintiffs. An affirmative defense is a reason given by the defendant for why the plaintiff should not win the lawsuit, even if what the plaintiff says is true. See, e.g., MDS (Canada), Inc. v. Rad Source Techns., Inc., 720 F.3d 833, 850 (11th Cir. Florida Rules of Civil Procedure. There are several defenses to counter a claim of breach of warranty. In those cases, you may be able to not only win your case, but recover money from the other side. And lastly, the party must prove that it has sustained damages, such as financial losses, due breach of contract. Affirmative Defenses to Breach of Warranty. Model Form of Verdict for Breach of Contract, Form 416.5 Model Form of Verdict for Oral or Written Contract Terms, Form 416.6 Model Form of Verdict for Contract Implied in Fact, Form 416.7 Model Form of Verdict for Contract Implied in Law, Form 416.8 Model Form of Verdict for Contract FormationOffer, Form 416.10 Model Form of Verdict for Contract FormationAcceptance, Form 416.11 Model Form of Verdict for Contract FormationAcceptance by Silence Or Conduct, Form 416.12 Model Form of Verdict for Substantial Performance of Contract, Form 416.13 Model Form of Verdict for Modification of Term(s) Of Contract, Form 416.14 Model Form of Verdict for InterpretationDisputed Term(s), Form 416.15 Model Form of Verdict for InterpretationMeaning of Ordinary Words, Form 416.16 Model Form of Verdict for InterpretationMeaning of Disputed Technical or Special Words, Form 416.17 Model Form of Verdict for InterpretationConstruction of Contract as a Whole, Form 416.18 Model Form of Verdict for InterpretationConstruction by Conduct, Form 416.19 Model Form of Verdict for Interpretation of ContractReasonable Time, Form 416.20 Model Form of Verdict for InterpretationConstruction Against Drafter, Form 416.21 Model Form of Verdict for Existence of Conditions Precedent Disputed, Form 416.22 Model Form of Verdict for Occurrence of Agreed Condition Precedent of Contract Claim, Form 416.24.

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