A civil conspiracy is a combination of two or more persons who agree to act together to inflict a wrong or an injury upon another, or who agree to act together to commit a lawful act using unlawful means to inflict a wrong or injury upon another. An agreement may be made orally, or in writing, or may be implied by the conduct of the parties. An agreement may be proved from evidence there was knowledge the wrongful act was contemplated, there was collaboration, the contemplated act was adhered to, and one or more of the alleged co-conspirators participated in the act. In order for a civil conspiracy to be found to exist, one of the parties to the alleged conspiracy must commit an act in pursuit of the agreement and the conspiracy was a proximate cause of damage.

It is alleged that the unlawful act [or means] was_____________ [name tort or illegal conduct, e.g., deceit, assault]. The elements which must be proved are: [Insert elements.] * * * * *