N.C.P.I.—Crim. 239.80

The defendant has been charged with [transporting] [keeping] a child

outside the State with intent to violate a custody order.

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

prove four things beyond a reasonable doubt:

First, that the defendant [[took] [transported] a child outside the limits

of the State] [caused the child to be [taken] [transported] outside the limits

of the State] [kept the child outside the limits of the State].

Second, that at that time the child had not yet reached his sixteenth

birthday.

Third, an order of a [federal] [state] court awarded custody of the

child to a person other than the defendant.

And Fourth, that the defendant, by so acting, intended to violate this

order. (If you find beyond a reasonable doubt that the defendant kept the

child outside the limits of the State in violation of this court order for a

period in excess of seventy­ two hours, you may infer that the defendant

intended to violate the court order at the time. However, you are not

compelled to do so. You will consider this evidence together with all other

evidence in this case in determining whether the State has proved beyond a

reasonable doubt that the defendant intended to violate this court order.)

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

about the alleged date, the defendant [took] [transported] [caused to be

taken] [caused to be transported] [kept] outside the State a child who had

not yet reached his sixteenth birthday with the intent to violate the order of

a [federal] [state] court awarding custody of the child to a person other than

the defendant, 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 your duty to return a verdict of not guilty.