N.C.P.I.—Civil 800.70

The (state number) issue reads:

“Did the defendant intrude offensively upon the privacy of the

plaintiff?”2

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, three

things:

First, that the defendant intruded upon the privacy of the plaintiff.3

Such an intrusion occurs when the solitude, seclusion, private affairs or

personal concerns of a person are invaded.4 The invasion may be

physical5 or mental.6

Second, that the defendant's intrusion was intentional. An act is

intentional when it is done knowingly, or with purpose, or with reckless

indifference to its consequences.7

And Third, that a reasonable person, under the same or similar

circumstances, would be highly offended by such intrusion.8

Finally, as to the (state number) issue on which the plaintiff has

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

the defendant intruded offensively upon the privacy of the plaintiff, 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.