Brennan v. Northern Electric Co.

This is an action in conversion to recover the value of an automobile. In her complaint, plaintiff alleges that at all times therein mentioned she was the owner of a certain Buick automobile which, on May 2, 1921, was in the possession of the Franklin Garage, a corporation, with which she had left it as security for the payment of the sum of $90, being the balance of the purchase price thereof.

Paragraph 4 of the complaint reads: “That on the second day of May, 1921, and at all times thereafter, this plaintiff was prepared to and did offer to pay the said Franklin Garage the said sum of ninety…