COLJI-Crim. 8-2:04

The elements of the crime of introducing contraband in the first

degree (introduction into) are:

1. That the defendant,

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

3. knowingly and unlawfully,

4. introduced, or attempted to introduce, a dangerous instrument,

5. into a detention facility or at any location where an inmate was

or was likely to be located,

6. while the inmate was in the custody and under the jurisdiction

of a political subdivision of the state of Colorado or the

department of corrections, but not on parole.

[7. 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 introducing contraband in the first degree

(introduction into).

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 introducing contraband in the

first degree (introduction into).