Unlawful Methamphetamine Trafficking -- Possession

Unlawful Methamphetamine Trafficking -- Possession With Intent to Manufacture, Distribute, or Dispense: H.R.S. § 712-1240.6(1) and (2) [In Count (count number) of the Indictment/Complaint, the] [The] Defendant, (defendant’s name), is charged with the offense of Unlawful Methamphetamine Trafficking. A person commits the offense of Unlawful Methamphetamine trafficking if he/she knowingly possesses with intent to [manufacture] [distribute] [dispense] one or more preparations, compounds, mixtures, or substances of methamphetamine, or any of its salts, isomers, and salts of isomers. There are two material elements of the offense of Unlawful Methamphetamine Trafficking, 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 knowingly possessed one or more preparations, compounds, mixtures, or substances of methamphetamine, or any of its salts, isomers, and salts of isomers; and 2. That the Defendant did so with intent to [manufacture] [distribute] [dispense] the one or more preparations, compounds, mixtures, or substances. Notes H.R.S. § 712-1240.6(1) and (2). For definition of states of mind, see instructions: For definition of terms defined by H.R.S. Chapter 712, see instructions: For definition of “possession,” see instruction 6.06. If the defendant is charged under H.R.S. § 712-1240.6(2), then the court must also submit instructions 13.53A and 13.53B to the jury.