COLJI-Crim. 6.5:04

The elements of the crime of caretaker neglect or endangerment of an

at-risk person are:

1. That the defendant,

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

3. knowingly,

4. committed caretaker neglect against, or acted in a manner likely

to be injurious to the physical or mental welfare of,

5. an at-risk person.

[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 caretaker neglect or endangerment of an at-risk

person.

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 caretaker neglect or

endangerment of an at-risk person.