Haw. Pattern Jury Instr. (Criminal) 12.18

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

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

of Perjury.

A person commits the offense of Perjury if he/she makes, in

any official proceeding, under an oath [required] [authorized]

by law, a false statement which he/she does not believe to be

true.

There are five material elements of the offense of Perjury,

each of which the prosecution must prove beyond a reasonable

doubt.

These five elements are:

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

(name of county), the Defendant made a false statement; and

2. That the Defendant did not believe the statement to be

true; and

3. That the Defendant did so under oath [required]

[authorized] by law; and

4. That the Defendant did so in an official proceeding;

and

[5. That the Defendant did so intentionally, knowingly or

recklessly.]