COLJI-Crim. 18:74

The elements of the crime of unlawfully furnishing or omitting

material information are:

1. That the defendant,

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

3. knowingly,

4. furnished false or fraudulent material information in, or

omitted any material information from,

5. a[n] [insert description of application, report, or other

document required to be kept or filed under article 18 of title

18; part 1 of article 280 of title 12; part 2 of article 80 of title 27;

or any record required to be kept by article 18 of title 18; part 1

of article 280 of title 12; or part 2 of article 80 of title 27].

[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 unlawfully furnishing or omitting material

information.

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 unlawfully furnishing or

omitting material information.