COLJI-Crim. 3-3:13

The elements of the crime of violation of custody (court order) are:

1. That the defendant, whether or not he [she] was the child’s

parent,

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

3. violated an order of any district or juvenile court of this state,

granting the custody of a child or parental responsibilities with

respect to a child under the age of eighteen to any person,

agency, or institution,

4. with the intent,

5. to deprive the lawful custodian or person with parental

responsibilities of the custody or care of a child under the age

of eighteen.

[6. 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 (court order).

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 (court

order).