Alaska Criminal Pattern Jury Instruction 11.41.260

, the defendant in this case, has been charged with the crime of stalking in the first degree.

To prove that the defendant committed this crime, the state must prove beyond a reasonable doubt the following:

(1) the defendant knowingly engaged in repeated acts of nonconsensual contact involving the victim or a family member of victim;

(2) the defendant, by engaging in those repeated acts of nonconsensual contact, recklessly placed the victim in fear of [death or physical injury] [the death or physical injury of the victim’s family member]; [and]

[(3) the defendant was subject to conditions of [probation] [release before trial] [release after conviction] [parole] and the repeated acts of nonconsensual contact violated one of those conditions.]

[(3) the defendant’s acts of nonconsensual contact violated an order issued or filed under ***.]

[(3) the victim was under 16 years of age.]

[(3) the defendant possessed a deadly weapon at any time while engaged in those acts of nonconsensual contact.]

[(3) the defendant has a previous conviction for [stalking in first degree] [stalking in the second degree] [violating a protective order].]

[(3) the defendant has a previous conviction for [attempted] [solicitation to commit] [murder in any degree] [manslaughter] [criminally negligent homicide] [murder of an unborn child] [manslaughter of an unborn child] [criminally negligent homicide of an unborn child] [assault in any degree] [reckless endangerment] [kidnapping] [custodial interference in any degree] [human trafficking in any degree] [sexual assault in any degree] [sexual abuse of a minor in any degree] [incest] [online enticement of a minor] [unlawful exploitation of a minor] [indecent exposure in any degree] [terroristic threatening in any degree] [harassment in any degree] that involved the same victim as the present offense.]