A person who abducts another or, having abducted another, continues to restrain the other person with intent to [hold the victim for ransom or reward] [use the victim as a shield or hostage] [hold the victim in a condition of involuntary servitude] [terrorize the victim or a third person] [commit a felony or attempt to commit a felony] [interfere with the performance of any governmental or political function] is guilty of Kidnapping.
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, _______________, [abducted] [having abducted, continued to restrain] _______________; and
2) The Defendant did so intending to [hold _______________ for ransom or reward] [use _______________ as a shield or hostage] [hold _______________ in a condition of involuntary servitude] [terrorize _______________ or a third person] [commit a felony or attempt to commit a felony] [interfere with the performance of any governmental or political function].
DEFINITIONS [Insert relevant definitions. NDCC 12.1-01-04, 12.1-02-02, 12.1-18-04.]
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