[A person is guilty of assault if the person willfully causes substantial bodily injury to another human being.]
[A person is guilty of assault if the person negligently causes substantial bodily injury to another human being by means of a firearm, destructive device, or other weapon, the use of which against a human being is likely to cause death or serious bodily injury.]
[Insert relevant definitions. NDCC 12.1-01-04 and 12.1-02-02]
The State's burden of proof is satisfied only if the evidence shows, beyond a reasonable doubt, the following essential elements of the offense charged:
1. On or about the ____ day of _______________, 19__, in ______________ County, North Dakota, the defendant, _______________, caused substantial bodily injury to ______________.
2. The defendant willfully caused the injury.
Or
The Defendant negligently caused the injury by means of a firearm, destructive device, or other weapon, the use of which against a human being is likely to cause death or serious bodily injury.
NDCC 12.1-17-01.1