RECKLESS ENDANGERING IN THE FIRST DEGREE – WIDELY DANGEROUS MEANS

RECKLESS ENDANGERING IN THE FIRST DEGREE – WIDELY DANGEROUS MEANS: H.R.S. § 707-713 [In Count (count number) of the Indictment/Complaint, the] [The] Defendant, (defendant's name), is charged with the offense of Reckless Endangering in the First Degree. A person commits the offense of Reckless Endangering in the First Degree if he/she employs widely dangerous means in a manner which recklessly places another person in danger of death or serious bodily injury. There are three material elements of the offense of Reckless Endangering in the First Degree, 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 employed widely dangerous means; and 2. That the Defendant did so intentionally, knowingly or recklessly; and 3. That the Defendant did so in a manner which recklessly placed another person in danger of death or serious bodily injury. Notes H.R.S. §§ 707-713, 702-206(1), (2) and (3). For definition of states of mind, see instructions: For definition of terms defined by H.R.S. Chapter 707, see instruction: For definition of terms not defined by H.R.S. Chapter 707, see instruction: