23.12(1) [1989 New] Verdict Directing-Conversion-Taking

Instruction No 1 23.12(1) [1989 New] Verdict Directing--Conversion--Taking Your verdict must be for plaintiff if you believe: First, plaintiff was (here describe facts which entitled plaintiff to possession-- e.g.--"the owner of the watch", "the lessee of the automobile"), and Second, defendant took possession of (here describe the property) with the intent to exercise some control over (here describe the property), and Third, defendant thereby deprived plaintiff of the right to possession of (here describe the property). * [unless you believe that plaintiff is not entitled to recover by reason of Instruction No. (here insert number of affirmative defense instruction ) ].