N.C.P.I.—Crim. 227.20

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

prove two things beyond a reasonable doubt.

First, that the defendant is the owner1 of the massage and

bodywork therapy establishment.2

Second, that the defendant knowingly [[engaged in] [permitted any

person(s) to engage in] sexual activity in the defendant’s massage and

bodywork therapy establishment] [[used] [permitted any person(s) to

use] the defendant’s massage and bodywork therapy establishment to

make arrangements to engage in sexual activity in another place.] Sexual

activity is [masturbation, whether done alone or with another human or

an animal] [vaginal, anal, or oral intercourse3 whether done with another

human or with an animal] [touching, in an act of apparent sexual

stimulation or sexual abuse, of the clothed or unclothed genitals, pubic

area, or buttocks of another person or the clothed or unclothed breasts of

a human female] [an act or condition that depicts torture, physical

restraint by being fettered or bound, or flagellation of or by a person clad

in undergarments or in revealing or bizarre costume] [excretory functions]

[the insertion of any part of a person’s body, other than the male sexual

organ, or any object into another person’s anus or vagina, except when

done as part of a recognized medical procedure] [the lascivious exhibition

of the genitals or pubic area of any person].

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

about the alleged date that the defendant was the owner of the massage

and bodywork therapy establishment and that the defendant [[engaged

in] [permitted any person(s) to engage in] sexual activity in the

defendant’s massage and bodywork therapy establishment] [[engaged in

using] [permitted any person(s) to use] the defendant’s massage and

bodywork therapy establishment to make arrangements to engage in

sexual activity in another place then 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, it would be your duty to return a verdict of

not guilty.