PROHIBITED ACTS RELATED TO VISITS TO MORE THAN

PROHIBITED ACTS RELATED TO VISITS TO MORE THAN ONE PRACTITIONER TO OBTAIN CONTROLLED SUBSTANCE PRESCRIPTIONS: H.R.S. § 329-46 [In Count (count number) of the Indictment/Complaint, the] [The] Defendant, (defendant's name), is charged with the offense of Prohibited Acts Related To Visits To More Than One Practitioner To Obtain Controlled Substance Prescriptions. A person commits the offense of Prohibited Acts Related To Visits To More Than One Practitioner To Obtain Controlled Substance Prescriptions if he/she visits more than one practitioner and intentionally or knowingly withholds information regarding previous practitioner visits for the purpose of obtaining (specify controlled substance(s)) prescriptions for quantities that exceed what any single practitioner would have [prescribed] [dispensed] for the time period and legitimate medical purpose represented. There are three material elements of the offense of Prohibited Acts Related To Visits To More Than One Practitioner To Obtain Controlled Substance Prescriptions, each of which the prosecution must prove beyond a reasonable doubt. These three elements are: 1. That, on or about (date) in the [City and] County of (name of county), the Defendant intentionally or knowingly visited more than one practitioner; 2. That the Defendant intentionally or knowingly withheld information regarding previous practitioner visits; and 3. That the Defendant did so for the purpose of obtaining (specify controlled substance(s)) prescriptions for quantities that exceeded what any single practitioner would have [prescribed] [dispensed] for the time period and legitimate medical purposes represented. Notes H.R.S. §§ 329-46, 702-206(1) and (2). For definition of states of mind, see instructions: The state of mind requirement may be deleted from element one of the instruction by agreement of the parties.