COLJI-Crim. 5-3:02

The elements of the crime of fraud in effecting sales (less than

represented quantity) are:

1. That the defendant,

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

3. knowingly,

4. in the course of business,

5. sold, offered, or exposed for sale or delivered less than the

represented quantity of any commodity or service.

[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 fraud in effecting sales (less than represented

quantity).

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 fraud in effecting sales (less than

represented quantity).