COLJI-Crim. 13:07.3

The elements of the crime of intentional misrepresentation of

entitlement to an assistance animal are:

1. That the defendant,

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

3. intentionally,

4. misrepresented entitlement to an animal in his [her] possession

as an assistance animal,

5. for the purpose of obtaining any of the rights or privileges set

forth in state or federal law for an individual with a disability

as a reasonable accommodation in housing, and

6. he [she] was previously given a written or verbal warning

regarding the fact that it is illegal to intentionally misrepresent

entitlement to an assistance animal, and

[7. he [she] knew that the animal was not an assistance animal

with regard to him [her].]

[7. he [she] knew that he [she] did not have a disability.]

[8. 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 intentional misrepresentation of entitlement to an

assistance animal.

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 intentional misrepresentation

of entitlement to an assistance animal.