COLJI-Crim. 5-1:05

The elements of the crime of forgery (officially issued or created) are:

1. That the defendant,

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

3. with intent,

4. to defraud,

5. falsely made, completed, altered, or uttered a written

instrument,

6. that was, or that purported to be, or that was calculated to

become or to represent if completed,

7. a written instrument officially issued or created by a public

office, public servant, or government agency.

[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 forgery (officially issued or created).

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 forgery (officially issued or

created).