KIDNAPPING -- FACILITATE FELONY OR FLIGHT

KIDNAPPING -- FACILITATE FELONY OR FLIGHT: H.R.S. § 707-720(1)(c) [In Count (count number) of the Indictment/Complaint, the] [The] Defendant, (defendant's name), is charged with the offense of Kidnapping. A person commits the offense of Kidnapping if he/she intentionally or knowingly restrains another person with intent to facilitate the commission of a felony or flight thereafter. There are three material elements of the offense of Kidnapping, 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 restrained another person; and 2. That the Defendant did so intentionally or knowingly; and 3. That the Defendant did so with the intent to facilitate the commission of a felony or flight thereafter.* Notes H.R.S. §§ 707-720(1)(c), 702-206(1) and (2). For definition of states of mind, see instructions: For definition of terms defined by H.R.S. Chapter 707, see instruction: *The court should identify whether applicable or included offenses are felonies, and instruct as to the elements of these felonies (and any applicable defenses that vitiate intent), if the felony offenses are not otherwise charged.