COLJI-Crim. 3-2:10.5

The elements of the crime of assault in the second degree (peace

officer, firefighter, or emergency medical service provider—serious bodily

injury) are:

1. That the defendant,

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

3. with intent,

4. to prevent a person whom he [she] knew, or should have

known, to be a peace officer, firefighter, or emergency medical

service provider from performing a lawful duty,

5. intentionally,

6. caused serious bodily injury to any person.

[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 assault in the second degree (peace officer,

firefighter, or emergency medical service provider—serious bodily injury).

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 assault in the second degree

(peace officer, firefighter, or emergency medical service provider—serious

bodily injury).