COLJI-Crim. 3-4:49

The elements of aggravated sexual assault on a client by a

psychotherapist (therapeutic deception) are:

1. That the defendant,

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

3. knowingly,

4. inflicted sexual penetration or intrusion on another person,

5. when the defendant was a psychotherapist, and

6. the person was a client of the defendant, and

7. the sexual penetration or intrusion occurred by means of

therapeutic deception.

[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 aggravated sexual assault on a client by a

psychotherapist (therapeutic deception).

After considering all the evidence, if you decide the prosecution has

not proven 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 (therapeutic deception).