COLJI-Crim. 18:53

The elements of the crime of retail sale of methamphetamine

precursor drugs (delivery of an excess amount within twenty-four hours)

are:

1. That the defendant,

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

3. knowingly,

4. delivered in or from a store,

5. to the same individual,

6. during any twenty-four-hour period,

7. more than three and six-tenths grams of a methamphetamine

precursor drug or a combination of two or more

methamphetamine precursor drugs.

[8. 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 retail sale of methamphetamine precursor drugs

(delivery of an excess amount within twenty-four hours).

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 retail sale of methamphetamine

precursor drugs (delivery of an excess amount within twenty-four hours).