Haw. Pattern Jury Instr. (Criminal) 10.09A

HRS § 708-822(1)(b)

(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 Third Degree.

A person commits the offense of Criminal Property Damage in

the Third Degree if he/she intentionally damages the property of

another, without the other’s consent, in an amount exceeding

[$500*] [$100].

There are four material elements of the offense of Criminal

Property Damage in the Third Degree, each of which the

prosecution must prove beyond a reasonable doubt.

These four elements are:

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

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

and

2. That the Defendant did so without the other=s consent;

and

3. That the damage to the property exceeded [$500*]

[$100]; and

4. That the Defendant acted intentionally as to each of

the foregoing elements.