N.C.P.I.—Crim. 226.72E

The defendant has been charged with the cyber-bullying of a school

employee.

For you to find the defendant1 guilty of this offense, the State must

prove five things beyond a reasonable doubt:

First, that the defendant used a [computer] [computer network];

Second, that without the authorization of the school employee, the

defendant signed up2 (name school employee) [for electronic mailing

lists] [to receive junk electronic messages and instant messages];

Third, that the defendant had the intent to [intimidate] [torment]

that school employee;

Fourth, that the defendant was a student at (name school);

And Fifth, that the victim of the cyber-bullying was a school

employee.3

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

about the alleged date the defendant was a student and used a

[computer] [computer network] to sign up a school employee [for

electronic mailing lists] [to receive junk electronic messages and instant

messages] without the school employee’s authorization and with the

intent to intimidate or torment that school employee, it would be your

duty to return a verdict of guilty. If you do not so find or have a

reasonable doubt as to one or more of these things, then it would be

your duty to return a verdict of not guilty.