COLJI-Crim. 8-7:01

The elements of the crime of bribing a witness or victim (testimony)

are:

1. That the defendant,

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

3. offered, conferred, or agreed to confer,

4. any benefit upon a witness, or a victim, or a person the

defendant believed was to be called to testify as a witness or

victim in any official proceeding, or upon a member of the

witness’s family, a member of the victim’s family, a person in

close relationship to the witness or victim, or a person residing

in the same household as the witness or victim,

5. with intent,

6. to influence the witness or victim to testify falsely or unlawfully

withhold any testimony.

[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 bribing a witness or victim (testimony).

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 bribing a witness or victim

(testimony).