COLJI-Crim. 9-3:13

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

(false message) are:

1. That the defendant,

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

3. knowingly,

4. sent or delivered a false message or furnished or conspired to

furnish such message to an operator to be sent or delivered,

5. with intent,

6. to injure, deceive, or defraud any person, corporation, or the

public.

[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 abuse of telephone and telegraph service (false

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 (false message).