A person who [knowingly abducts another person] [knowingly restrains another person under terrorizing circumstances or under circumstances exposing the person to risk of serious bodily injury] [willfully restrains another with intent to hold the person in a condition of involuntary servitude] is guilty of Felonious Restraint.

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, ____________;

2) [Knowingly abducted ____________, another human being] [Knowingly restrained _____________, another human being, under terrorizing circumstances or under circumstances exposing _____________ to risk of serious bodily injury] [Willfully restrained ____________, another human being, with the intent to hold ____________ in a condition of involuntary servitude].

DEFINITIONS [Insert relevant definitions. NDCC 12.1-01-04, 12.1-02-02, 12.1-18-04.] “Terrorizing circumstances” are circumstances involving threats of violence, or acts dangerous to human life made with an intent to induce fear.

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