COLJI-Crim. 9-1:64

The elements of the crime of terrorist training activities are:

1. That the defendant,

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

3. taught or demonstrated to any person the use, application, or

making of any firearm, explosive, or incendiary device, or

technique capable of causing injury or death to any person,

knowing that it would be unlawfully used in furtherance of a

civil disorder; or assembled with one or more other persons for

the purpose of training or practicing with, or being instructed

in the use of, any firearm, explosive or incendiary device, or

technique capable of causing injury or death to any person,

with the intent to unlawfully use the same in furtherance of a

civil disorder.

[4. 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 terrorist training activities.

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 terrorist training activities.