COLJI-Crim. 4-4:31

The elements of the crime of theft of medical records or medical

information are:

1. That the defendant,

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

3. knowingly,

[4. without proper authorization,

5. obtained a medical record or medical information with the

intent to appropriate the medical record or medical information

to his [her] own use or to the use of another.]

[4. without proper authorization,

5. stole or disclosed to an unauthorized person a medical record

or medical information.]

[4. without authority,

5. made or caused to be made a copy of a medical record or

medical information.]

[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 theft of medical records or medical information.

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 of medical records or

medical information.