N.C.P.I.—Civil 807.00

The (state number) issue reads:

"Did the defendant wrongfully interfere with a contract right

between the plaintiff and (name other party to contract)?"

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:1

First, that a valid contract right existed between the plaintiff and

(name other party to contract).

Second, that the defendant had knowledge of the facts giving rise

to the plaintiff's contract right with (name other party to contract). (It

does not matter that the defendant was mistaken as to the legal

significance of these facts or that the defendant believed that no contract

right existed.2)

Third, that the defendant intentionally3 induced (name other party

to contract) [not to perform] [to alter adversely the performance of]4 [not

to renew]5 [to terminate] the contract right to which the plaintiff was

entitled.

Fourth, that the defendant acted without justification.6

And Fifth, that the defendant's actions resulted in actual damages

to the plaintiff.

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 wrongfully interfered with a contract right between the

plaintiff and (name other party to contract), 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.