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IN THE _____________________COURT OF _______________________ (County), ___________________________________ (State) _________________________________________ PLAINTIFF(Name of Plaintiff)V.CAUSE NO. _______,_________________________________________________ DEFENDANT(Name of Defendant) INSTRUCTION NO. _____________________ You are instructed that if you find from the evidence that before and at the time of the alleged conversion the plaintiff was the owner of the property in question, and entitled to the immediate possession of it and that while the plaintiff was the owner and entitled to possession, and before the commencement of this suit, the defendant wrongfully took the property into his/her possession, this will constitute a wrongful conversion of the property, and you should find the defendant guilty. In such case it is wholly immaterial whether or not the plaintiff made a demand for the property before commencing the suit.

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