COLJI-Crim. 13:62

The elements of the crime of prohibited bail bond activity (induce to

commit crime) are:

1. That the defendant,

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

3. was engaged in the business of writing bail bonds, and

4. coerced, suggested, aided and abetted, offered promise of

favor, or threatened any person on whose bail bond the

defendant was surety, or offered to become surety to induce

that person to commit any crime.

[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 prohibited bail bond activity (induce to commit

crime).

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 prohibited bail bond activity

(induce to commit crime).