N.C.P.I.—Crim. 240.88

The defendant has been charged with failing to report that

defendant [witnessed] [had knowledge of] an accidental injury to a

client.1

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

must prove three things beyond a reasonable doubt:

First, that the defendant was a(n) [employee] [volunteer] at

(name facility), a facility whose primary purpose is to provide services

for the [care] [treatment] [habilitation] [rehabilitation] of individuals

with [mental illness] [developmental disabilities] [substance abuse

disorders].

Second, that the defendant [witnessed] [had knowledge of] an

accidental injury to a client2.

And Third, that the defendant failed to report3 that defendant

[witnessed] [had knowledge of] an accidental injury to a client, to

(name person), who was an authorized person designated by the

facility to receive reports of employee and volunteer violations.

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

or about the alleged date the defendant was a(n) [employee]

[volunteer] at (name facility), a facility whose primary purpose is to

provide services for the [care] [treatment] [habilitation] [rehabilitation]

of individuals with [mental illness] [developmental disabilities]

[substance abuse disorders], and that the defendant failed to report

that the defendant [witnessed] [had knowledge of] an accidental injury

to a client, to (name person), who was an authorized personnel

designated by the facility to receive reports of employee and volunteer

violations, 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, then it would be your duty to return a verdict of not

guilty.