COLJI-Crim. 4-4:40

The elements of the crime of altering or removing a vehicle

identification number (with knowledge) are:

1. That the defendant,

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

3. knowingly,

4. possessed, purchased, disposed of, sold, or transferred a motor

vehicle or a major component motor vehicle part with

knowledge that it contained a removed, changed, altered,

counterfeited, defaced, destroyed, disguised, falsified, forged,

or obliterated vehicle identification number, manufacturer’s

number, or engine number unless such motor vehicle or major

component motor vehicle part was [insert factors relevant to

establish compliance with the provisions of section 42-5-110].

[5. 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 knowledge).

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 knowledge).