COLJI-Crim. 4-4:39

The elements of the crime of altering or removing a vehicle

identification number (with intent) are:

1. That the defendant,

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

3. knowingly,

4. removed, changed, altered, counterfeited, defaced, destroyed,

disguised, falsified, forged, or obliterated the vehicle

identification number, manufacturer’s number, or engine

number of a motor vehicle or major component motor vehicle

part,

5. with an intent to misrepresent the identity or prevent the

identification of a motor vehicle or major component motor

vehicle part.

[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 altering or removing a vehicle identification

number (with intent).

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 altering or removing a vehicle

identification number (with intent).