COLJI-Crim. 9-1:39

The elements of the crime of harassment (repeated 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. made repeated communications,

6. at inconvenient hours,

7. that invaded the privacy of another and interfered in the use

and enjoyment of another’s home, private residence, or private

property.

[8. 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 (repeated 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 (repeated

communication).