UJI 14-331. Stalking; essential elements.

For you to find the defendant guilty of stalking [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 pursued a pattern of conduct by, on more than one occasion, [directly or indirectly] [or] [using a third party2]3 engaging in any of the following acts: [(a) following __________________ (name of person)] [(b) monitoring __________________ (name of person)] [(c) placing __________________ (name of person) under surveillance] [(d) threatening __________________ (name of person)] [(e) communicating [to] [or] [about] _____________ (name of person)];3 [2. In pursuing the pattern of conduct the defendant was not acting within the scope of [lawful employment] [or] [constitutionally protected activity,]3]4 3. [Although some of the acts constituting the pattern of conduct were directed at other people, the] [The]3 overall pattern of conduct was directed at ________________ (name of victim); 4. The defendant intended [to place __________________ (name of victim) in reasonable apprehension of [death] [bodily harm] [sexual assault] [confinement or restraint]] [or] [to cause __________________ (name of victim) to reasonably fear the [death] [bodily harm] [sexual assault] [confinement or restraint] of ______________ (name(s) of other individual(s))].3, 5 5. This happened in New Mexico [between] [on or about] the ____________ day of ______________, ________ [and the __________________ day of ______________, _________].3, 6