COLJI-Crim. 18:87

The elements of the crime of making, distributing, or possessing a

counterfeit drug implement are:

1. That the defendant,

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

3. knowingly or intentionally,

4. made, distributed, or possessed a punch, die, plate, stone, or

other thing designed to print, imprint, or reproduce the

trademark, trade name, or other identifying mark, imprint, or

device of another or any likeness of any of the foregoing upon

any drug or container or labeling thereof.

[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, distributing, or possessing a counterfeit

drug implement.

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, distributing, or

possessing a counterfeit drug implement.