COLJI-Crim. 3-4:48

The elements of aggravated sexual assault on a client by a

psychotherapist are:

1. That the defendant,

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

3. knowingly,

4. inflicted sexual intrusion or penetration on another person,

5. when the defendant was a psychotherapist, and

6. when the person was a client of the defendant.

[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 aggravated sexual assault on a client by a

psychotherapist.

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 aggravated sexual assault on a

client by a psychotherapist.