COLJI-Crim. 18:90

The elements of the crime of advertisement of drug paraphernalia

are:

1. That the defendant,

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

3. placed an advertisement in any newspaper, magazine, handbill,

or other publication, and

4. intended thereby to promote the sale in Colorado of equipment,

products, or materials designed and intended for use as drug

paraphernalia.

[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 advertisement of drug paraphernalia.

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 advertisement of drug

paraphernalia.