Haw. Pattern Jury Instr. (Criminal) 15.10

HRS § 134-9

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

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

of Carrying Firearm on Person Without License.

A person commits the offense of Carrying Firearm on Person

Without License if he/she carries on his/her person a pistol or

revolver, whether concealed or unconcealed, without a license to

carry.

There are five material elements of the offense of Carrying

Firearm on Person Without License, 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 knowingly carried on his/her

person the object in question, whether concealed or unconcealed;

and

2. That the object in question was a pistol or revolver;

and

3. That, at the time he/she carried the object in

question, the Defendant believed, knew, or recklessly

disregarded the substantial and unjustifiable risk, that the

object was a pistol or revolver; and

4. That, at that time, the Defendant did not have a

license to carry; and

5. That, at that time, the Defendant believed, knew, or

recklessly disregarded the substantial and unjustifiable risk,

that he/she did not have a license to carry.

“License to carry” means a license to carry a pistol or

revolver and ammunition therefor issued by the chief of police

of the [City and] County of (name of county).