COLJI-Crim. 4-4:01

The elements of the crime of theft (intent to permanently deprive)

are:

1. That the defendant,

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

3. knowingly,

[4. obtained, retained, or exercised control over anything of value

of another,

5. without authorization or by threat or deception, and]

[4. received, loaned money by pawn or pledge on, or disposed of,

5. anything of value or belonging to another that he [she] knew or

believed to have been stolen, and]

6. intended to deprive the other person permanently of the use or

benefit of the thing of value.

[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 theft (intent to permanently deprive).

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 theft (intent to permanently

deprive).