COLJI-Crim. 18:34

The elements of the crime of fraudulent representation of a medical

condition related to medical marijuana are:

1. That the defendant,

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

3. fraudulently,

4. represented a medical condition to a physician, the Department

of Public Health and Environment, or a state or local law

enforcement official,

5. for the purpose of falsely obtaining a marijuana registry

identification card from the Department of Public Health and

Environment, or for the purpose of avoiding arrest and

prosecution for a marijuana-related offense.

[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 fraudulent representation of a medical condition

related to medical marijuana.

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 fraudulent representation of a

medical condition related to medical marijuana.