COLJI-Crim. 3-6:02

The elements of the crime of stalking (credible threat and repeated

communication) are:

1. That the defendant,

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

3. knowingly,

4. made a credible threat to another person, either directly, or

indirectly through a third person, and

5. in connection with the threat, repeatedly made any form of

communication with that person, a member of that person’s

immediate family, or someone with whom that person was

having or previously had a continuing relationship, regardless

of whether a conversation ensued.

[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 stalking (credible threat and repeated

communication).

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 stalking (credible threat and

repeated communication).