N.C.P.I.—Crim. 214.45

The defendant has been charged with felonious breaking or entering

into a place of religious worship without the consent of the [owner] [tenant]

and with the intent to commit a felony.

For you to find the defendant guilty of this offense, the State must

prove four things beyond a reasonable doubt.

First, that there was

a. [a breaking 1 by the defendant. (State how breaking allegedly

occurred) would be a breaking.]

b. [an entry by the defendant. (State how entry allegedly occurred)

would be an entry.]

c. [either a breaking1 or an entry by the defendant. (State how

breaking allegedly occurred) would be a breaking. (State how

entry allegedly occurred) would be an entry.]

Second, that the building [broken into] [entered] [broken into or

entered] was a place of religious worship.

Third, that the [owner] [tenant] did not consent to the [breaking]

[entering] [breaking or entering].

And Fourth, that at the time of the [breaking] [entering] [breaking or

entering], the defendant intended to commit the [felony of (name felony)] 2

[larceny]

If you find from the evidence beyond a reasonable doubt that on or

about the alleged date, the defendant [broke into] [entered] [broke into or

entered] a building that was a place of religious worship without the consent

of the [owner] [tenant], intending at that time to commit the [felony of

(name felony)] [larceny], it would be your duty to return a verdict of guilty.

If you do not so find or if you have a reasonable doubt as to one or

more of these things, it would be do your duty to return a verdict of not

guilty. 3