N.C.P.I.—Civil 800.72

The (state number) issue reads:

“Did the defendant disclose (a) private image(s) of the plaintiff?”

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, five

things:2

First, that the defendant knowingly disclosed3 (an) image(s)4 of the

plaintiff with the intent to:

[Coerce, harass, intimidate, demean, humiliate, or cause financial

loss to the plaintiff]; [or]

[Cause others to coerce harass, intimidate, demean, humiliate, or

cause financial loss to the plaintiff.]

Second, that the plaintiff is identifiable from the disclosed [image

itself] [images themselves] or information offered in connection with the

image(s).

Third, that the plaintiff’s intimate parts5 are exposed or the plaintiff

is engaged in sexual conduct6 in the disclosed image(s).

Fourth, that the defendant disclosed the image(s) without the

affirmative consent of the plaintiff; and

Fifth, that the defendant obtained the image(s) without consent of

the plaintiff or under circumstances such that the defendant knew or

should have known that the plaintiff expected the image(s) to remain

private.7

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 disclosed (a) private image(s) 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.