UJI 14-319. Deprivation of property; household member; essential elements.

For you to find the defendant guilty of deprivation of property of a household member [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 intentionally2 deprived ________________ (name of victim) of the use of [separate] [community] [or] [jointly owned]3 personal property of ________________ (name of victim); 2. The defendant intended to [intimidate] [threaten]3 ________________ (name of victim); 3. ________________ (name of victim) was a household member of the defendant;4 4. This happened in New Mexico on or about the __________ day of ______________, ________.