[A person who willfully causes substantial bodily injury to another human being is guilty of Assault.]

[A person who negligently causes substantial bodily injury to another human being by means of a firearm, destructive device, or other weapon, the use of which against a human being is likely to cause death or serious bodily injury is guilty of Assault.]

[A person who willfully causes substantial bodily injury to another human being under the age of twelve years is guilty of Assault.] [A person who negligently causes substantial bodily injury to another human being under the age of twelve years by means of a firearm, destructive device, or other weapon, the use of which against a human being is likely to cause death or serious bodily injury is guilty of Assault.]

ESSENTIAL ELEMENTS OF OFFENSE

The State's burden of proof is satisfied if the evidence shows, beyond a reasonable doubt, the following essential elements:

1) On or about [month] [day] [year], in [County], North Dakota, the Defendant, _______________, caused substantial bodily injury to _______________; and

2) [The Defendant willfully caused the injury] [The Defendant negligently caused the injury by means of a firearm, destructive device, or other weapon, the use of which against a human being is likely to cause death or serious bodily injury]. [3) The victim was under the age of twelve years.]

DEFINITIONS [Insert relevant definitions. NDCC 12.1-01-04, 12.1-02-02.]

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