COLJI-Crim. 9-3:12

The elements of the crime of abuse of telephone and telegraph service

(divulging message) are:

1. That the defendant

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

3. was an employee of a telegraph or telephone company, and

4. knowingly,

5. divulged the contents or the purport of any message or part

thereof sent or intended to be sent to any person other than one

to whom said message was sent or person authorized to receive

the same.

[6. 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 abuse of telephone and telegraph service (divulging

message).

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 abuse of telephone and

telegraph service (divulging message).