COLJI-Crim. 13:64

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

return) 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. failed to return any nonforfeited collateral or security, other

than the bond fee, within fourteen days after receipt of a copy

of the court order that resulted in a release of the bond by the

court, and

5. the collateral did not also secure another obligation, premium

payment plan, or bail recovery fee, and

6. [three] [six] years had not yet elapsed from the date the bond

was posted when the court released the bond.

[7. 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 (failure to return).

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

(failure to return).