COLJI-Crim. 3-4:55

The elements of invasion of privacy for sexual gratification are:

1. That the defendant,

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

3. knowingly,

4. observed or took a photograph of another person’s intimate

parts,

5. without the person’s consent,

6. in a situation where the person observed or photographed had

a reasonable expectation of privacy,

7. for the purpose of the observer’s own sexual gratification.

[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 invasion of privacy for sexual gratification.

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 invasion of privacy for sexual

gratification.