COLJI-Crim. 20:25

The elements of the crime of gaming fraud (work without license)

are:

1. That the defendant,

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

3. without first obtaining the requisite license or registration

pursuant to the Limited Gaming Act of 1991,

4. was employed, worked, or otherwise acted in a position whose

duties required licensing or registration pursuant to said Act.

[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 gaming fraud (work without license).

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 gaming fraud (work without

license).