Any person who commits [name of crime] as a crime of violence or crime of pecuniary gain for the benefit of, at the direction of, or in association with any criminal street gang, with the intent to promote, further, or assist in the affairs of a criminal gang, or obtain membership into a criminal gang, is guilty of Criminal Street Gang Crime.
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;
2) The Defendant, _________, committed [name of crime] as a crime of [violence] [pecuniary gain];
3) Willfully [for the benefit of] [at the direction of] [in association with] any criminal street gang; and
4) With the intent to [(promote)(further)(assist) in the affairs of a criminal gang] [obtain membership into a criminal gang].
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