A person who intentionally starts or maintains a fire or causes an explosion and thereby recklessly [places another person in danger of death or bodily injury] [places [an entire or any part of a building or inhabited structure of another] [a vital public facility] in danger of destruction] [causes damage to property of another constituting a pecuniary loss in excess of two thousand dollars] is guilty of Endangering by Fire or Explosion.

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, _______________, intentionally [started or maintained a fire] [caused an explosion]; and

2) The Defendant recklessly [placed _______________ in danger of death or bodily injury] [placed [an entire or any part of _______________, a building or inhabited structure of another] [_______________, a vital public facility] in danger of destruction] [caused damage of _______________ to the property of another constituting pecuniary loss in excess of two thousand dollars].

DEFINITIONS [Insert relevant definitions. NDCC 12.1-01-04, 12.1-02-02, 12.1-21-08.]

*****