401.18b Issues on Plaintiff's Claim - General Negligence - Two Drivers' Negligence The [next] issues you must decide on (claimant)'s claim against (defendant) are: whether (defendant) or (defendant) was negligent or whether both were negligent in operating the vehicles, and, if so, whether that negligence was a legal cause of [loss] [injury] [or] [damage] to (claimant, decedent, or person for whose injury claim is made).