COLJI-Crim. 16:06

The elements of the crime of improper holding of a valuable article

are:

1. That the defendant,

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

3. knowingly,

4. was a purchaser, and

[5. failed to hold a valuable article, other than stamped and

assayed gold or silver bullion or gold coins, within the

jurisdiction of purchase for a period of thirty days from the

date of purchase.]

[5. while holding a valuable article, other than stamped and

assayed gold or silver bullion or gold coins, within the

jurisdiction of purchase for a period of thirty days from the

date of purchase, failed to hold the article separate and apart

from any other transaction.]

[5. while holding a valuable article, other than stamped and

assayed gold or silver bullion or gold coins, within the

jurisdiction of purchase for a period of thirty days from the

date of purchase, changed in form or altered the article in any

way.]

[5. while holding a valuable article, other than stamped and

assayed gold or silver bullion or gold coins, within the

jurisdiction of purchase for a period of thirty days from the

date of purchase, failed to permit a requesting law enforcement

officer to inspect the article during the thirty-day period.]

[6. 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 improper holding of a valuable article.

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 improper holding of a valuable

article.