KIDNAPPING – RANSOM, HOSTAGE, INTERFERENCE WITH GOVERNMENTAL FUNCTION

KIDNAPPING – RANSOM, HOSTAGE, INTERFERENCE WITH GOVERNMENTAL FUNCTION: H.R.S. § 707-720(1)(a),(b) and (f) [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 [hold that person for ransom or reward] [use that person as a shield or hostage] [interfere with the performance of any governmental or political function]. 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 [hold that person for ransom or reward] [use that person as a shield or hostage] [interfere with the performance of any governmental or political function]. Notes H.R.S. §§ 707-720(1)(a),(b) and (f), 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: