Haw. Pattern Jury Instr. (Criminal) 14.07B

H.R.S. §§ 705-520, 708-831(1)(b), 708-830(2)

[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 theft in

the second degree, he/she agrees with one or more persons that

[they] [one or more of them] would obtain or exert control over

the property of another, the value of which exceeded $300.00, by

deception and with intent to deprive the other of the property

and that, [he/she] [a person who had joined the agreement]

commits an overt act for the purpose of carrying out the

agreement.

There are two material elements of the offense of Criminal

Conspiracy to commit theft in the second degree, each of which

the prosecution must prove beyond a reasonable doubt.

These two elements are:

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

(name of county), the Defendant with intent to promote or

facilitate the commission of theft in the second degree agreed

with one or more persons that [they] [one or more of them] would

obtain or exert control over the property of another, the value

of which exceeded $300.00, by deception and with intent to

deprive the other of the property; and

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

Defendant] [a person who had joined the agreement] with intent

to promote or facilitate the commission of theft in the second

degree committed an overt act(s) for the purpose of carrying out

the agreement, by (describe overt act(s)).

[In order to find the Defendant guilty, you must

unanimously agree as to the particular overt act committed.]