UJI 14-318. Criminal damage to property; household member; essential elements.

For you to find the defendant guilty of criminal damage to property of a household member [household member’s interest in excess of $1,000.00]1 [as charged in Count ______],2 the state must prove to your satisfaction beyond a reasonable doubt each of the following elements of the crime: 1. The defendant intentionally3 damaged [real] [personal] [community] [or] [jointly owned]4 property of ________________ (name of victim); 2. The defendant intended to [intimidate] [threaten] [or] [harass]4 (name of victim); [3. The defendant did not have the ________________’s (name of victim) permission to damage the property];5 [4. The damage to the ________________’s (name of victim) interest in the property was more than $1,000.00];1 5. ________________ (name of victim) was a household member of the defendant;6 6. This happened in New Mexico on or about the __________ day of ______________, ________.