COLJI-Crim. 13:24

The elements of the crime of unlawful sale or trade of secondhand

property (records) are:

1. That the defendant,

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

3. was a secondhand dealer, and

[4. failed to make a record containing all required information, as

defined in these instructions,

5. of each sale or trade of secondhand property made by him

[her], his [her] agent, or any person acting on his [her] behalf,

6. which sale or trade equaled or exceeded thirty dollars in value

for each item.]

[4. failed to make available to a peace officer for inspection at a

reasonable time,

5. a record containing all required information, as defined in these

instructions.]

[4. failed to mail or deliver a record containing all required

information, as defined in these instructions,

[5. of a sale or trade of secondhand property made by him [her],

his [her] agent, or any person acting on his [her] behalf,

6. which sale or trade equaled or exceeded thirty dollars in value

for each item,

7. to a local law enforcement agency within three days of the date

of such sale or trade.]

[4. failed to keep a copy of a record containing all required

information, as defined in these instructions,

5. of a sale or trade of secondhand property made by him [her],

his [her] agent, or any person acting on his [her] behalf,

6. which sale or trade equaled or exceeded thirty dollars in value

for each item,

7. for at least one year after the date of the sale or trade.]

[_. 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 sale or trade of secondhand property

(records).

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 sale or trade of

secondhand property (records).