It is unlawful to willfully [create] [deliver] [possess with intent to deliver] a counterfeit substance.
ESSENTIAL ELEMENTS OF THE 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) Willfully [created] [delivered] [possessed with intent to deliver] a counterfeit substance.