N.C.P.I.—Crim. 238.22B

The defendant has been charged with second degree sexual exploitation

of a minor.

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

two things beyond a reasonable doubt:

First, that the defendant [distributed] [transported] [exhibited]

[received] [sold] [purchased] [exchanged] [solicited] a child sex doll. 1

And Second, that the defendant knew the [character] [content] of the

material.

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

about the alleged date, the defendant [distributed] [transported] [exhibited]

[received] [sold] [purchased] [exchanged] [solicited] a child sex doll and that

the defendant knew the [character] [content] of the material, 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.

NOTE WELL: N.C. Gen. Stat. § 14-190.17(c) provides that mistake

of age is not a defense to prosecution.

N.C. Gen. Stat. § 14-190.17(b) states that “[i]n a prosecution

under this section, the trier of fact may infer that a participant in

sexual activity whom material through its title, text, visual

representations, or otherwise represents or depicts as a minor is

a minor.”