N.C.P.I.—Crim. 270.60B

The defendant has been charged with unsafe movement causing

[property damage in excess of five thousand dollars ($5,000)] [[serious

bodily injury to a motorcycle [operator] [passenger]].

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

prove five things beyond a reasonable doubt:

First, that the defendant drove a vehicle on a [highway] [public

vehicular area];

Second, that defendant [started] [stopped] [turned] the vehicle from

a direct line;

Third, that before [starting] [stopping] [turning] the defendant did not

see that the movement could be made in safety. It is not required that the

circumstances be absolutely free from danger. In determining whether the

driver can [start] [stop] [turn] with safety, the driver has the right to

assume, in the absence of circumstances indicating the contrary, that other

drivers will exercise reasonable care to avoid colliding with the driver’s

vehicle;

Fourth, that when the defendant [started] [stopped] [turned] the

defendant caused a motorcycle operator to [change travel lanes] [leave that

portion of a [public street] [highway] designated as travel lanes];

And Fifth, that the defendant’s actions resulted in a crash causing

[property damage in excess of five thousand dollars ($5,000)] [[serious

bodily injury to a motorcycle [operator] [passenger]].

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

about the alleged date, the defendant drove a vehicle on a [highway] [public

vehicular area], that the defendant [started] [stopped] [turned the vehicle

from a direct line], that the [start] [stop] [turn] could not be made safety,

that when the defendant [started] [stopped] [turned] there was a

motorcycle operator who was affected by this movement and defendant

caused this motorcycle operator to [change travel lanes] [leave that portion

of a [public street] [highway] designated as travel lanes], and that the

defendant’s actions resulted in a crash causing [property damage in excess

of five thousand dollars ($5,000)] [[serious bodily injury to a motorcycle

[operator] [passenger]], it would be your duty to return a verdict of

responsible. 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

responsible.