“Plaintiff claims that Defendant wrongfully exercised control over his personal property. To establish this claim, Plaintiff must prove all of the following: 1. That Plaintiff owned/possessed/had a right to possess an item of personal property; 2. That Defendant substantially interfered with Plaintiff’s property by knowingly or intentionally did one or more of the following: taking possession of the item of personal property; preventing Plaintiff from having access to the item of personal property; destroying the item of personal property; or, refusing to return the item of personal property after Plaintiff demanded its return; 3. That Plaintiff did not consent; 4. That Plaintiff was harmed; and 5. That Defendant’s conduct was a substantial factor in causing Plaintiff’s harm.”
[CACI Jury Instructions [citations omitted]]
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