14-330. Harassment; essential elements.
For you to find the defendant guilty of harassment 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 maliciously pursued a pattern of conduct that was intended to [annoy] [seriously alarm] [or] [terrorize]2 ______________________________ (name of victim);
2. A reasonable person would have suffered substantial emotional distress as a result of the defendant's actions;
3. The defendant's conduct served no lawful purpose;
4. This happened in New Mexico on or about the ______________ day of ________________________, ________.
USE NOTE
1. Insert the count number if more than one count is charged.
2. Use only the applicable bracketed alternatives.
[Adopted, effective February 1, 1995.]