UJI 14-2404 NMRA
UJI 14-2404. Retaliation against a witness.
For you to find the defendant guilty of retaliation against a witness [as charged in
Count ________]1, the state must prove to your satisfaction beyond a reasonable doubt
each of the following elements of the crime:
[1. The defendant knowingly engaged in conduct that caused:
[[bodily injury to ________________________ (name of person)] [or]
[damage to the tangible property of ________________________ (name of
person)
[OR]
[1. The defendant knowingly threatened:
[bodily injury to ________________________ (name of person)] [or]
[damage to the tangible property of ________________________ (name of
person)];
2. The defendant engaged in the conduct with the intent to retaliate against
________________________ (name of witness) for providing any information to a law
enforcement officer relating to:
[the commission or possible commission of ________________________ (name of
felony)2;] [or]
[a violation of conditions of probation;] [or]
[a violation of conditions of parole;] [or]
[a violation of conditions of release pending judicial proceedings;]
3. This happened in New Mexico on or about the __________ day of
______________, __________.