COLJI-Crim. 20:38

The elements of the crime of unauthorized use or possession of

cheating or thieving device are:

1. That the defendant,

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

3. used or possessed while on the premises,

4. a cheating or thieving device, including tools, drills, wires,

coins, or tokens attached to strings or wires or electronic or

magnetic devices,

5. to facilitate the alignment of any winning combination or to

facilitate removing from any slot machine any money or

contents thereof, and

6. he [she] was not a duly authorized gaming employee acting in

the furtherance of his [her] employment.

[7. 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 unauthorized use or possession of cheating or

thieving device.

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 unauthorized use or possession

of cheating or thieving device.