COLJI-Crim. 17:01

The elements of the crime of use of proceeds derived from a pattern

of racketeering activity or the collection of an unlawful debt are:

1. That the defendant,

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

3. knowingly,

4. received any proceeds derived, directly or indirectly, from a

pattern of racketeering activity or through the collection of an

unlawful debt, and

5. used or invested, whether directly or indirectly, any part of

such proceeds or the proceeds derived from the investment or

use thereof in the acquisition of any title to, or any right,

interest, or equity in, real property or in the establishment or

operation of any enterprise.

[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 use of proceeds from derived from a pattern of

racketeering activity or the collection of an unlawful debt.

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 use of proceeds derived from a

pattern of racketeering activity or the collection of an unlawful debt.