Haw. Pattern Jury Instr. (Criminal) 10.05B

DANGER OF DEATH OR BODILY INJURY:

H.R.S. § 708-820(1)(a)

(Applicable to offenses that occurred on or before June 8, 2006)

[In Count (count number) of the Indictment/Complaint, the]

[The] Defendant, (defendant’s name), is charged with the offense

of Criminal Property Damage in the First Degree.

A person commits the offense of Criminal Property Damage in

the First Degree if he/she intentionally or knowingly damages

property and thereby recklessly places another person in danger

of death or bodily injury.

There are three material elements of the offense of

Criminal Property Damage in the First Degree, each of which the

prosecution must prove beyond a reasonable doubt.

These three elements are:

1. That, on or about (date) in the [City and] County of

(name of county), the Defendant damaged the property; and

2. That the Defendant did so intentionally or knowingly;

and

3. That such conduct recklessly placed another person in

danger of death or bodily injury.