Haw. Pattern Jury Instr. (Criminal) 14.07

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

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

of Criminal Conspiracy.

A person commits the offense of Criminal Conspiracy if,

with intent to promote or facilitate the commission of a crime,

he/she agrees with one or more persons that [they] [one or more

of them] will [engage in or solicit (designate conduct specified

by the definition of the alleged agreed crime)] [cause or

solicit (designate result specified by the definition of the

alleged agreed crime)] and [he/she] [a person who had joined the

agreement] commits an overt act for the purpose of carrying out

the agreement.

There are three material elements of the offense of

Criminal Conspiracy, 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 agreed with one or more persons

that [they] [one or more of them] would [engage in or solicit

(designate conduct specified by the definition of the alleged

agreed crime)] [cause or solicit (designate result specified by

the definition of the alleged agreed crime)]; and

2. That, while the agreement was in effect, [the

Defendant] [a person who had joined the agreement] committed

[one or more of] the following overt act[s] for the purpose of

carrying out the agreement (list overt act[s] for which there is

sufficient evidence); and

3. That the Defendant joined in the agreement with intent

to promote or facilitate the commission of (specify substantive

offense), and the overt act was also committed with such intent.

A person commits the offense of (specify substantive

offense) if . . .

There are (number) elements of the (specify substantive

offense) . . .

These (number) elements are: (List elements numerically).

[In order to find the Defendant guilty, you must

unanimously agree as to the particular overt act committed.]