N.C.P.I.—Crim. 270.66

The defendant has been charged with failing to stop for an

approaching law enforcement vehicle displaying a blue light and sounding a

siren causing serious injury or death.

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

prove seven things beyond a reasonable doubt:

First, that the defendant was operating a vehicle. (Describe vehicle) is

a vehicle.

Second, that the defendant was doing so on a [street] [highway].

(Describe highway) is a highway.

Third, that while the defendant was doing so, a law enforcement

vehicle approached. 1 A (describe police vehicle) is a law enforcement

vehicle.

Fourth, that the law enforcement vehicle was displaying a blue

warning light. 2

Fifth, that the law enforcement vehicle was also sounding a siren 3

audible under normal conditions from a distance of not less than 1,000 feet.

Sixth, that the defendant [did not immediately drive his vehicle to a

position as near as possible and parallel to the right hand [edge] [curb] of

the highway, clear of any intersections, and stop] [after stopping properly,

did not remain in that position until [otherwise directed by a [police] [traffic]

officer] [the (describe vehicle) had passed].] 4

And Seventh, that in doing so, the defendant caused [serious injury]

[death] to a [law enforcement officer] [firefighter] [emergency vehicle

operator] [(name other emergency response person)] in the immediate area

of the authorized [emergency vehicle] [public service vehicle].

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

about the alleged date the defendant was operating a vehicle on a highway,

that while he was doing so a law enforcement vehicle approached displaying

a blue warning light and sounding a siren audible under normal conditions

from a distance of not less than 1,000 feet, that the defendant [did not

immediately drive his vehicle to a position as near as possible and parallel to

the right hand [edge] [curb] of the highway, clear of any intersections, and

stop] [after stopping properly, did not remain in that position until

[otherwise directed by a [police] [traffic] officer] [the (describe vehicle) had

passed], and that in doing so, the defendant caused [serious injury] [death]

to a [law enforcement officer] [firefighter] [emergency vehicle operator]

[(name other emergency response person)] in the immediate area of the

authorized [emergency vehicle] [public service vehicle], 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. 5