Haw. Pattern Jury Instr. (Criminal) 9.61

H.R.S. § 707-756

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

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

of Electronic Enticement of a Child in the First Degree.

A person commits the offense of Electronic Enticement of a

Child in the First Degree if he/she uses a computer, or any

other electronic device, to intentionally or knowingly

communicate [with a minor whom he/she knows to be under the age

of eighteen years] [with another person in reckless disregard of

the risk that the person is under the age of eighteen and the

person is, in fact, under the age of eighteen] [with another

person who represents himself/herself to be under the age of

eighteen], with the intent to promote or facilitate the

commission of [Murder in the First Degree] [Murder in the Second

Degree] [(specify Class A felony)] [(specify offense listed in

HRS § 846E-1)], agrees to meet [with the minor whom he/she knows

to be under the age of eighteen] [with the other person in

reckless disregard of the risk that the person is under the age

of eighteen and who was, in fact, under the age of eighteen]

[with the other person who represented himself/herself to be

under the age of eighteen] and he/she intentionally or knowingly

travels to the agreed upon meeting place at the agreed upon

meeting time.

There are five material elements of the offense of

Electronic Enticement of a Child in the First Degree, 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 used a computer or any other

electronic device; and

2. That the Defendant intentionally or knowingly did so

to communicate with [a minor known by the Defendant to be under

the age of eighteen] [another person in reckless disregard of

the risk that the person was under the age of eighteen and the

person was, in fact, under the age of eighteen] [another person

who represented himself/herself to be under the age of

eighteen]; and

3. That the Defendant agreed to meet [with the minor whom

he/she knew to be under the age of eighteen] [with the other

person in reckless disregard of the risk that the person was

under the age of eighteen and who was, in fact, under the age of

eighteen] [with the other person who represented himself/herself

to be under the age of eighteen]; and

4. That the Defendant did so with the intent to promote

or facilitate the commission of the offense of [Murder in the

First Degree] [Murder in the Second Degree] [(specify Class A

felony)] [(specify offense listed in HRS § 846E-1)]*; and

5. That the Defendant intentionally or knowingly traveled

to the agreed upon meeting place at the agreed upon meeting

time.