A person who willfully [engages in sexual contact with another person] [causes another person to engage in sexual contact] is guilty of Gross Sexual Imposition if the actor compels another person to submit by force or by threat of imminent death, serious bodily injury, or kidnapping, to be inflicted on any human being.
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, , willfully [engaged] [caused _______________ to engage] in sexual contact with _______________;
2) The Defendant did so by willfully compelling _______________ to submit by force or by threat of imminent death, serious bodily injury, or kidnapping, to be inflicted on , a human being[.] [;and]
[3) In the course of the offense, the Defendant inflicted serious bodily injury on_______________.]
[4) As a result of injuries sustained during the course of the offense, ________________ died.]
DEFINITIONS [Insert relevant definitions. NDCC 12.1-01-04, 12.1-02-02, 12.1-20-02.]