COLJI-Crim. 5-9:03

The elements of the crime of identity theft (falsely made, completed,

altered, or uttered) are:

1. That the defendant,

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

3. with the intent,

4. to defraud,

5. falsely made, completed, altered, or uttered a written

instrument or financial device containing any personal

identifying information or financial identifying information of

another.

[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 identity theft (falsely made, completed, altered, or

uttered).

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 identity theft (falsely made,

completed, altered, or uttered).