COLJI-Crim. 13:12

The elements of the crime of unlawful purchase or sale of commodity

metals or detached catalytic converters (book or register) are:

1. That the defendant,

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

3. was an owner, keeper, or proprietor of a junk shop, junk store,

salvage yard, or junk cart or other vehicle, or a collector of or

dealer in junk, salvage, or other secondhand property, and

[4. failed to keep a book or register detailing all transactions

involving commodity metals or detached catalytic converters.]

[4. the defendant’s book or register involving commodity metals or

detached catalytic converters did not include [insert a

description of the relevant requirement(s) from section 18-13-

111(1)(b)–(d)].]

[5. 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 unlawful purchase or sale of commodity metals or

detached catalytic converters (book or register).

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 unlawful purchase or sale of

commodity metals or detached catalytic converters (book or register).