12.5 BURNING TO DEFRAUD INSURER 817.233, Fla. Stat. To prove the crime of Burning to Defraud an Insurer, the State must prove the following four elements beyond a reasonable doubt: 1. [Name of defendant] [set fire to] [burned] [attempted to set fire to] the burning of] [building, structure or personal property alleged]. 2. The property belonged to [person alleged]. 3. The property was insured against loss or damage by fire. 4. [Name of defendant] acted willfully and with a fully-formed, conscious intent to injure or defraud the insurer of the property. "Willfully" means intentionally, knowingly and purposely.