USE OF A COMPUTER IN THE COMMISSION OF A SEPARATE

USE OF A COMPUTER IN THE COMMISSION OF A SEPARATE CRIME: H.R.S. § 708-893 [In Count (count number) of the Indictment, the] [The] Defendant, (defendant’s name) is charged with the offense of Use of a Computer In the Commission of a Separate Crime. A person commits the offense of Use of a Computer In the Commission of a Separate Crime if he/she knowingly uses a computer to identify, select, solicit, persuade, coerce, entice, induce, or procure the victim or intended victim of [custodial interference in the first degree] [custodial interference in the second degree] [sexual assault in the second degree] [sexual assault in the third degree] [sexual assault in the fourth degree] [promoting child abuse in the second degree] [promotion pornography for minors]. There are two material elements of the offense of Use of a Computer In the Commission of a Separate Crime, 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 used a computer; and 2. That the Defendant did so knowingly to identify, select, solicit, persuade, coerce, entice, induce, or procure the victim or intended victim of [custodial interference in the first degree] [custodial interference in the second degree] [sexual assault in the second degree] [sexual assault in the third degree] [sexual assault in the fourth degree] [promoting child abuse in the second degree] [promotion pornography for minors].* Notes For definition of states of mind, see instructions: For a definition of terms defined by H.R.S. Chapter 708 Part IX, see instruction 18.00. *The court should instruct as to the elements of the included offense, unless such offense is otherwise charged.