A person who willfully [tampers with tangible property of another person so as to endanger person or property] [damages tangible property of another person] is guilty of criminal mischief.
[Insert relevant definitions. NDCC 12.1-01-04 and 12.1-02-02]
The State's burden of proof is satisfied if the evidence shows, beyond a reasonable doubt, the following essential elements:
1. On or about the ____ day of _______________, 19__, in ______________ County, North Dakota, the Defendant, _______________, willfully [tampered with _____________, tangible property of _____________, so as to endanger persons or property] [damaged ___________________, tangible property of _____________________].
[2. The Defendant intentionally caused pecuniary loss in excess of ten thousand dollars.]
[2. The Defendant intentionally caused pecuniary loss in excess of two thousand dollars.]
[2. The Defendant damaged tangible property of another by means of an explosive or destructive devise.]
[2. The Defendant recklessly caused pecuniary loss in excess of two thousand dollars.]
[2. The Defendant intentionally caused pecuniary loss of one hundred dollars or more.]
NDCC 12.1-21-05
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