N.C.P.I.—Crim. 271.62

The defendant has been charged with removal of a vehicle from the

scene of an accident resulting in [damage to property] [[injury] [death] to

any person about which the defendant did not know or have reason to

know].

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

prove four things beyond a reasonable doubt:

First, that the defendant was the driver of a vehicle that was involved

in a reportable accident. A reportable accident 1 is one involving a motor

vehicle that results in [death or injury of a human being] [total property

damage of one thousand dollars ($1,000) or more] [property damage of any

amount to a vehicle seized because it was driven by a person charged with

an offense involving impaired driving whose license was already revoked as

a result of a prior impaired driving offense].

Second, that the defendant knew or reasonably should have known

that the vehicle was involved in an [accident] [collision] resulting in [damage

to property] [[injury] [death] to any person about which the defendant did

not know or have reason to know].

Third, that defendant willfully [facilitated] [allowed] [agreed to] the

removal of the vehicle from the scene of the accident (without justification

or excuse). 2

And Fourth, that a law enforcement officer had not [completed the

investigation of the accident] [authorized the removal of the vehicle].

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

about the alleged date the defendant was the driver of a vehicle that was

involved in a reportable accident, that the defendant knew or reasonably

should have known that the vehicle was involved in an [accident] [collision]

resulting in [damage to property] [[injury] [death] to any person about

which the defendant did not know or have reason to know], that the

defendant willfully [facilitated] [allowed] [agreed to] the removal of the

vehicle from the scene of the accident before a law enforcement officer had

[completed the investigation of the accident] [authorized the removal of the

vehicle] (without jurisdiction or excuse), 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.