N.C.P.I.—Crim. 235.18

The defendant has been charged with willfully communicating

threats.

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

prove five things beyond a reasonable doubt:

First, that the defendant willfully threatened to [physically injure

the victim (or the victim's child, sibling, spouse or dependent)) [damage

the property of another]. A threat is any expression of an intent or

determination to [physically injure] [damage the property of] another. A

threat is made willfully if it is made intentionally or knowingly.

Second, that the threat was communicated to the victim [orally] [in

writing] [by any other means].

Third, that the threat was made in a manner and under

circumstances which would cause a reasonable person to believe that it

was likely to be carried out.

Fourth, that the victim believed that the threat would be carried

out.

And Fifth, that the threat was made without lawful authority.

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

about the alleged date the defendant willfully and without lawful authority

threatened to [physically injure the victim (or the victim's child, sibling,

spouse or dependent)\]) [damage the property of another], that this

threat was communicated to the victim [orally] [in writing] [by any other

means] in a manner and under such circumstances which would cause a

reasonable person to believe the threat was likely to be carried out, and

that the victim believed that the threat would be carried out, 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.