COLJI-Crim. 18:77

The elements of the crime of making a false statement related to a

controlled substance are:

1. That the defendant,

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

3. willfully,

4. made a false statement in any required order, report, or record

of [insert a description of the requirement, from article 18 of

title 18].

[5. 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 making a false statement related to a controlled

substance.

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 making a false statement

related to a controlled substance.