COLJI-Crim. 12-1:29

The elements of the crime of removal of a chemical, biological, or

radiological weapon are:

1. That the defendant,

2. in the State of Colorado, at or about the date and place charged,

3. removed or caused to be removed, or carried away,

4. a chemical, biological, or radiological weapon,

5. from the premises where the chemical, biological, or

radiological weapon was kept by the lawful user, vendor,

transporter, or manufacturer thereof,

6. without the consent or direction of the lawful possessor.

[7. and that the defendant’s conduct was not legally authorized by

the affirmative defense[s] in Instruction[s] ___.]

After considering all the evidence, if you decide the prosecution has

proven each of the elements beyond a reasonable doubt, you should find

the defendant guilty of removal of a chemical, biological, or radiological

weapon.

After considering all the evidence, if you decide the prosecution has

failed to prove any one or more of the elements beyond a reasonable doubt,

you should find the defendant not guilty of removal of a chemical,

biological, or radiological weapon.