N.C.P.I.—Civil 640.25

The (state number) issue reads:

"Did the defendant unlawfully [prevent] [attempt to prevent] the

plaintiff from obtaining employment?"

On this issue the burden of proof is on the plaintiff. This means

that the plaintiff must prove, by the greater weight of the evidence, two

things:1

First, the defendant had been the plaintiff's employer and had

discharged the plaintiff from its service.

Second, without solicitation, the defendant by oral or written

communication [prevented] [attempted to prevent] the plaintiff from

obtaining employment with another employer. (It would be lawful for the

defendant, upon request by a [person] [company] to whom the plaintiff

has applied for employment, to provide a truthful statement of the

reason the defendant discharged the plaintiff.)2

Finally, as to this issue on which the plaintiff has the burden of

proof, if you find by the greater weight of the evidence that the

defendant unlawfully [prevented] [attempted to prevent] the plaintiff

from obtaining employment, then it would be your duty to answer this

issue "Yes" in favor of the plaintiff.

If, on the other hand, you fail to so find, then it would be your duty

to answer this issue "No" in favor of the defendant.