COLJI-Crim. 13:17

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

metals or detached catalytic converters (record retention) 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 make a digital photographic record, video record, or

other record that identifies the seller and the commodity metal

or detached catalytic converter that the seller was selling.]

[4. made a digital photographic record, video record, or other

record that identifies the seller and the commodity metal or

detached catalytic converter that the seller was selling, but

failed to retain it for one hundred eighty days.]

[4. made a digital photographic record, video record, or other

record that identifies the seller and the commodity metal or

detached catalytic converter that the seller was selling; was an

owner; and did not permit a law enforcement officer to make

inspections of the record.]

[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 (record retention).

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 (record retention).