COLJI-Crim. 6-4:03

The elements of the crime of child abuse (knowing or reckless

excision or infibulation of female genitalia) are:

1. That the defendant,

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

[3. knowingly or recklessly,

4. excised or infibulated, in whole or in part,

5. the labia majora, labia minora, vulva, or clitoris of a female

child.]

[3. was a parent, guardian, or other person legally responsible for a

female child or charged with the care or custody of a female

child, and

4. knowingly or recklessly,

5. allowed the excision or infibulation, in whole or in part,

6. of the child’s labia majora, labia minora, vulva, or clitoris.]

[_. 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 child abuse (knowing or reckless excision or

infibulation of female genitalia).

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 child abuse (knowing or

reckless excision or infibulation of female genitalia).