COLJI-Crim. 5-5:09

The elements of the crime of issuance of a duplicate receipt not

marked 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 duplicate or additional negotiable

receipt for goods knowing that a former negotiable receipt for

the same goods or any part of them was outstanding and

uncancelled,

5. without placing upon the face thereof the word “duplicate.”

[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 duplicate receipt not marked.

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 duplicate receipt

not marked.