Haw. Pattern Jury Instr. (Criminal) 12.20

H.R.S. § 710-1070(2)

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

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

of Bribery by a Witness.

A person commits the offense of Bribery by a Witness if

he/she, [while a witness] [believing he/she is about to be

called as a witness] in any official proceeding, intentionally

[solicits] [accepts] [agrees to accept], directly or indirectly,

any benefit as consideration [which will influence his/her

testimony] [for avoiding or attempting to avoid legal process

summoning him/her to testify] [for absenting or attempting to

absent himself/herself from an official proceeding, to which

he/she has been legally summoned].

There are four material elements of the offense of Bribery

by a Witness, 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 [was a witness] [believed that

he/she was about to be called as a witness] in an official

proceeding; and

2. That, while [a witness] [so believing], the Defendant

[solicited] [accepted] [agreed to accept], directly or

indirectly, a benefit as consideration; and

3. That the Defendant did so [to influence the

Defendant's testimony] [to avoid or attempt to avoid legal

process summoning the Defendant to testify] [to absent or

attempt to absent the Defendant from an official proceeding, to

which the Defendant has been legally summoned]; and

4. That the Defendant did so intentionally.