COLJI-Crim. 5-5:07

The elements of the crime of issuance of a fraudulent receipt are:

1. That the defendant,

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

3. was a warehouse, or an officer, agent, or servant of a

warehouse, and

4. issued or aided in issuing a receipt,

5. knowing that the goods for which the receipt had been issued

had not been actually received by the warehouse, or were not

under the warehouse’s actual control at the time of issuing the

receipt.

[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 issuance of a fraudulent receipt.

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 issuance of a fraudulent

receipt.