COLJI-Crim. 5-1:19

The elements of criminal simulation (knowledge of true character)

are:

1. That the defendant,

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

3. with knowledge of an object’s true character, and

4. with intent,

5. to use to defraud,

6. uttered, misrepresented, or possessed any object that was made

or altered in such fashion that it appeared to have an antiquity,

rarity, source or authorship, ingredient, or composition which it

did not in fact have.

[7. 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 criminal simulation (knowledge of true character).

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 criminal simulation

(knowledge of true character).