UJI 14-240C. Homicide by vehicle; reckless driving; essential elements.

For you to find the defendant guilty of causing death by reckless driving [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 operated a motor vehicle2 in a reckless manner3; 2. The defendant’s reckless driving caused4 the death of ______________________________ (name of victim); 3. This happened in New Mexico on or about the _________ day of ______________, ________.