23.12(2) [1989 New] Verdict Directing-Conversion-Failure to Surrender Possession

Instruction No 1 23.12(2) [1989 New] Verdict Directing--Conversion--Failure to Surrender Possession 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 had possession of (here describe the property), and Third, plaintiff made a demand to defendant for possession of (here describe the property), and Fourth, thereafter defendant intentionally failed to return possession of (here describe the property) to plaintiff. * [unless you believe that plaintiff is not entitled to recover by reason of Instruction No. (here insert number of affirmative defense instruction ) ].