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(b) [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, procure, pursue, surveil, contact, harass, annoy, or alarm 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] [harassment] [harassment by stalking] [promoting 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, procure, pursue, surveil, contact, harass, annoy, or alarm 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] [harassment] [harassment by stalking] [promoting pornography for minors].* Notes H.R.S. §§ 708-893(b), 707-726, 707-727, 707-731, 707-732, 707-733, 707-751, 711-1106, 711-1106.5, 712-1215. For definition of states of mind, see instructions: For definition of terms defined by H.R.S. Chapter 708, see instruction 18.00. *The court should instruct as to the elements of the included offense, unless such offense is otherwise charged.