CRIMINAL PROPERTY DAMAGE IN THE SECOND DEGREE

CRIMINAL PROPERTY DAMAGE IN THE SECOND DEGREE WIDELY DANGEROUS MEANS: H.R.S. § 708-821(1)(a) (Applicable to offenses occurring on or after June 6, 2006) [In Count (count number) of the Indictment/Complaint, the] [The] Defendant, (defendant’s name), is charged with the offense of Criminal Property Damage in the Second Degree. A person commits the offense of Criminal Property Damage in the Second Degree if by means other than fire, he/she intentionally or knowingly damages the property of another, without the other’s consent, by the use of widely dangerous means. There are four material elements of the offense of Criminal Property Damage in the Second Degree, each of which the prosecution must prove beyond a reasonable doubt. These four elements are: 1. That, on or about (date) in the [City and] County of (name of county), by means other than fire, the Defendant damaged the property of another; and 2. That the Defendant did so without the other’s consent; and 3. That the Defendant did so by the use of widely dangerous means; and 4. That the Defendant did so intentionally or knowingly. Notes H.R.S. §§ 708-821(1)(a), 702-206(1) and (2). For definition of states of mind, see instructions: For definition of terms defined by H.R.S. Chapter 708, see instructions: