N.C.P.I.—Civil 800.74

NOTE WELL: This instruction1 is designed to be used

with N.C.P.I.—Civil 800.72 (“Invasion of Privacy –

Disclosure of Private Images”) and N.C.P.I.—Civil

800.73 (“Invasion of Privacy—Disclosure of Private

Images—Actual Damages”).

The (state number) issue reads:

“For how many days did the defendant disclose the plaintiff’s

private image?”2

If you have answered the (state number) issue “Yes” in favor of the

plaintiff, then you must determine for how many days the defendant

disclosed the plaintiff’s private image. 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 the number of days in total the defendant

transferred, published, distributed, or reproduced the plaintiff’s private

image.

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

the burdn of proof, it would be your duty to write the total number of

days that the defendant disclosed the plaintiff’s private image in the

blank space provided.