COLJI-Crim. 3-2:33

The elements of the crime of extortion (third party) are:

1. That the defendant,

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

3. without legal authority, and

4. with the intent,

5. to induce another person against that other person’s will to

perform an act or to refrain from performing a lawful act,

6. made a substantial threat to confine or restrain, cause economic

hardship or bodily injury to, or damage the property or

reputation of, the threatened person or another person, and

7. threatened to cause the result[s] by invoking action by a third

party, including but not limited to, the state or any of its

political subdivisions, whose interests were not substantially

related to the interests pursued by the defendant.

[8. 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 extortion (third party).

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 extortion (third party).