13.2 POSSESSION OF BURGLARY TOOLS 810.06, Fla. Stat. To prove the crime of Possession of Burglary Tools, the State must prove the following four elements beyond a reasonable doubt: 1. [Name of defendant] had possession of a mplement ]. 2. [Name of defendant] intended to use the tool in the commission of a burglary or trespass. 3. [Name of defendant] intended to commit a burglary or trespass. 4. [Name of defendant] did some overt act toward the commission of a burglary or trespass.