COLJI-Crim. 3-3:12

The elements of the crime of violation of custody (taking or enticing)

are:

1. That the defendant, whether or not he [she] was a natural or

foster parent of the child,

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

3. knowing that he [she] had no privilege to do so or heedless in

that regard,

4. took or enticed any child, under the age of eighteen, from the

custody or care of the child’s parents, guardian, or other lawful

custodian or person with parental responsibilities with respect

to the child.

[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 violation of custody (taking or enticing).

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 violation of custody (taking or

enticing).