COLJI-Crim. 13:38

The elements of the crime of abuse of property insurance (improperly

providing to insurance company) are:

1. That the defendant,

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

3. provided repairs, goods, or services, and

4. knowingly,

5. provided a rebate or a gift, cash, or thing of value,

6. to an insurance company or its representative, agent, employee,

or other acting on behalf of the insurance company,

7. in connection with any claim under an insurance policy which

insured for property damage.

[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 abuse of property insurance (improperly providing

to insurance company).

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 abuse of property insurance

(improperly providing to insurance company).