Del. P.J.I. Crim. No. 11.1471(l)(2)

PROHIBITED ACTS

In order to find Defendant guilty of Prohibited Acts, you must find the State

proved following three (3) elements beyond a reasonable doubt:

(1) Defendant [used/possessed with intent to use] any

[electronic/electric/mechanical] device [designed/constructed/programmed] to

assist [Defendant/another person] to keep track of cards played;

(2) Device was used at a video lottery facility including its [parking

area/adjacent facilities] without the permission of the Delaware Lottery Director;

and

(3) Defendant acted [intentionally/knowingly.]

.

“Intentionally” means it was Defendant’s conscious objective or purpose to

use or possess with the intent to use any electronic, electric or mechanical device

to keep track of cards played without the permission of the Delaware Lottery

Director while on the property of a video lottery facility.

“Knowingly” means Defendant was aware Defendant was using or

possessing with the intent to use any electronic, electric or mechanical device to

keep track of cards played without the permission of the Delaware Lottery

Director while on the property of a video lottery facility.