COLJI-Crim. 7-1:08

+ The elements of the [crime] [offense] of disclosing a private

intimate image or intimate digital depiction by a juvenile (image of

another) are:

1. That the [defendant] [juvenile],

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

3. while under eighteen years of age,

4. knowingly,

5. through digital or electronic means,

6. disclosed or threatened to disclose to the view of another

person,

7. a private intimate image or an intimate digital depiction of

another individual who was at least fourteen years of age or

was less than four years younger than the [defendant]

[juvenile],

[8. without the depicted individual’s consent.]

[8. when the recipient did not solicit or request to be supplied with

the private intimate image or intimate digital depiction and

suffered emotional distress.]

[8. when [he] [she] knew or should have known that the depicted

individual had a reasonable expectation that the private

intimate image or intimate digital depiction would remain

private.]

[9. and that the [defendant’s] [juvenile’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] [that the juvenile committed the offense] of

disclosing a private intimate image or intimate digital depiction by a

juvenile (image of another).

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] [that the juvenile did not

commit the offense] of disclosing a private intimate image or intimate

digital depiction by a juvenile (image of another).