A memorandum of law is written to a Court in support of a position taken by an attorney. No judge is going to ask to be "briefed" on so basic an issue. Moreover, the defendant, here is not charged with the actual "taking," he is charged with receiving stolen property. You need to do your own homework assigment or you're wasting a lot of money on law school.
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An informal memorandum of law is essentially supporting a legal position or argument in written form. Clearly there are several important differences between a civil suit for conversion and criminal prosecution for theft. The legal burdens of proof and rules of procedure are different in civil and criminal cases. You should be able to find several differences in the cases as requested by the judge.
Juan C. Garcia, Jr.
GARCIA LAW OFFICE, LLC