COLJI-Crim. 9-3:17

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

(bribery) are:

1. That the defendant,

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

3. knowingly,

4. bribed a telegraph or telephone operator or employee of a

telegraph or telephone company to disclose any private

message or the purport of the same received by him [her] by

reason of his [her] trust as agent of the company or used such

information when thus obtained.

[5. 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 (bribery).

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 (bribery).