301.11(a) Failure to Maintain Evidence or Keep a Record - Adverse Inference If you find that: [Name of party] [lost] [destroyed] [mutilated] [altered] [concealed] or otherwise caused the [describe evidence] to be unavailable, while it was within [his] [her] [its] possession, custody, or control; and the [describe evidence] would have been material in deciding the disputed issues in this case; then you may, but are not required to, infer that this evidence would have been unfavorable to [name of party]. You may consider this, together with the other evidence, in determining the issues of the case.