Queens, New York, is a diverse borough located in the southeastern part of New York City. It is known for its vibrant cultural mix, bustling neighborhoods, and numerous attractions. One type of instruction to a jury in Queens, New York, involves the concept that refusal to deliver goods after demand and tender of freight and storage charges can constitute conversion. Conversion is a legal term that refers to the unauthorized assumption or exercise of control over someone else's property, which is a civil offense. In Queens, New York, there are several types of instructions that could relate to the refusal to deliver goods. These may include: 1. Instruction on the elements of conversion: This instruction would outline the essential elements required to establish a claim of conversion. It may include elements such as the plaintiff's ownership/control over the goods, the defendant's intentional interference with the goods, and the resulting harm or damages caused. 2. Instruction on demand and tender of freight and storage charges: This instruction would explain the concept of demanding and tendering payment for freight and storage charges. It might outline the legal requirements for the plaintiff to make a proper demand and tender the appropriate charges before a refusal to deliver goods can be considered a conversion. 3. Instruction on the act of refusal to deliver goods: This instruction would focus on the actions or behaviors that constitute a refusal to deliver goods. It might involve scenarios where a defendant fails to release the goods to the rightful owner, despite a proper demand and tender of payment for freight and storage charges. 4. Instruction on damages in conversion cases: This instruction would provide guidance to the jury on how to assess damages in conversion cases related to the refusal to deliver goods. It might include instructions on evaluating the value of the goods, any financial losses incurred by the plaintiff, and any additional damages caused by the defendant's actions. Using these relevant keywords, an attorney or legal professional could prepare detailed content outlining the various aspects of a Queens, New York, instruction to a jury regarding the refusal to deliver goods after demand and tender of freight and storage charges, constituting conversion.