COLJI-Crim. 5-2:13

The elements of the crime of issuing a false financial statement

(representing in writing) 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. represented in writing that a written instrument purporting to

describe another person’s financial condition or ability to pay

as of a prior date was accurate with respect to that person’s

current financial condition or ability to pay,

6. knowing the instrument was materially false in that respect and

reasonably relied upon.

[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 issuing a false financial statement (representing in

writing).

After considering all the evidence, if you decide the prosecution has

failed to prove any one or more elements beyond a reasonable doubt, you

should find the defendant not guilty of issuing a false financial statement

(representing in writing).