COLJI-Crim. 4-4:03

The elements of the crime of theft (intentional use, concealment, or

abandonment) 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. used, concealed, or abandoned the thing of value,

7. intending that such use, concealment, or abandonment would

deprive the other person permanently of its use or benefit.

[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 theft (intentional use, concealment, or

abandonment).

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 (intentional use,

concealment, or abandonment).