COLJI-Crim. 5-4:01

The elements of the crime of commercial bribery (breach of a duty of

fidelity) are:

1. That the defendant,

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

3. knowingly,

4. solicited, accepted, or agreed to accept any benefit as

consideration for,

5. violating or agreeing to violate a duty of fidelity to which he

[she] was subject,

6. as agent or employee; or trustee, guardian, or other fiduciary;

or lawyer, physician, accountant, appraiser, or other

professional adviser; or officer, director, partner, manager, or

other participant in the direction of the affairs of an

incorporated or unincorporated association; or duly elected or

appointed representative or trustee of a labor organization or

employee welfare trust fund; or arbitrator or other purportedly

disinterested adjudicator or referee.

[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 commercial bribery (breach of a duty of fidelity).

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 commercial bribery (breach of

a duty of fidelity).