COLJI-Crim. 9-3:32.5

The elements of the crime of false statement to the CBI for sex

offender registry information are:

1. That the defendant,

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

3. submitted a false statement to the Colorado Bureau of

Investigation,

4. to obtain information from the sex offender registry.

[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 false statement to the CBI for sex offender registry

information.

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 false statement to the CBI for

sex offender registry information.