Haw. Pattern Jury Instr. (Criminal) 9.62

H.R.S. § 707-757

[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 Second Degree.

A person commits the offense of Electronic Enticement of a

Child in the Second 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] [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],

and, with the intent to promote or facilitate the commission of

a felony, 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 the person is, in fact, under the age of eighteen]

[with another person who represents himself/herself to be under

the age of eighteen], and 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 Second 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 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 he/she did so with the intent to promote or

facilitate the commission of the offense of (specify felony)*;

and

5. That he/she intentionally or knowingly traveled to the

agreed upon meeting place at the agreed upon meeting time.