ALTERATION OF FIREARM IDENTIFICATION MARKS

ALTERATION OF FIREARM IDENTIFICATION MARKS: H.R.S. § 134-10 [In Count (count number) of the Indictment/Complaint, the] [The] Defendant, (defendant's name), is charged with the offense of Alteration of Firearm Identification Marks. A person commits the offense of Alteration of Firearm Identification Marks if he/she knowingly [alters] [removes] [obliterates] the name of the make, model, manufacturer's number, or other mark(s) of identity of a firearm. There are two material elements of the offense of Alteration of Firearm Identification Marks, 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 [altered] [removed] [obliterated] the name of the make, model, manufacturer's number, or other mark(s) of identity of a firearm; and 2. That the Defendant did so knowingly. Notes H.R.S. §§ 134-10, 702-206(2). For definition of states of mind, see instruction: For definition of terms defined by H.R.S. Chapter 134, see instruction: For prima facie inference where Defendant had possession of a firearm or ammunition which has any mark of identity modified, see instruction 15.11A. Wilfully is satisfied if a person acts knowingly with respect to the elements of the offense. See H.R.S. § 702-210.