COLJI-Crim. 9-3:31

The elements of the crime of unlawful use of telecommunications

crime (cloning equipment; aiding or abetting) are:

1. That the defendant,

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

3. aided, abetted, advised, or encouraged one or more persons

who,

4. knowingly,

5. used cloning equipment to intercept signals, including signals

transmitted to or from cellular phones, between a

telecommunications provider and persons using

telecommunications services or between persons using

telecommunications services; or used cloning equipment to

create a cloned cellular phone.

[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 telecommunications crime (cloning equipment;

aiding or abetting).

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 telecommunications crime

(cloning equipment; aiding or abetting).