Haw. Pattern Jury Instr. (Criminal) 12.03

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

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

of Escape in the First Degree.

A person commits the offense of Escape in the First Degree

if he/she intentionally employs [physical force] [the threat of

physical force] [a dangerous instrument] against the person of

another in escaping from [a correctional facility] [a detention

facility] [custody].

There are three material elements of the offense of Escape

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 escaped from [a correctional

facility] [a detention facility] [custody]; and

2. That the Defendant employed [physical force] [the

threat of physical force] [a dangerous instrument] against the

person of another in escaping; and

3. That the Defendant did so intentionally.