COLJI-Crim. 9-1:36

The elements of the crime of harassment (communication) are:

1. That the defendant,

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

3. with intent,

4. to harass, annoy, or alarm another person,

[5. directly or indirectly initiated communication with a person or

directed language toward another person, anonymously or

otherwise,

6. by telephone, telephone network, data network, text message,

instant message, computer, computer network, computer

system, or other interactive electronic medium,

7. in a manner intended to threaten bodily injury or property

damage.]

[5. made any comment, request, suggestion, or proposal by

telephone, computer, computer network, computer system, or

other interactive electronic medium,

6. that was obscene.]

[_. 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 harassment (communication).

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 harassment (communication).