COLJI-Crim. 5-2:23

The elements of the crime of insurance fraud (false information) are:

1. That the defendant,

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

3. with an intent,

4. to defraud,

5. made, altered, presented, or caused to be presented a certificate

or other evidence of the existence of insurance in any form that

contained false material information or omitted material

information.

[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 insurance fraud (false information).

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 insurance fraud (false

information).