COLJI-Crim. 9-3:34.7

The elements of unlawfully making available on the internet personal

information about an election official are:

1. That the defendant,

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

3. knowingly,

4. made available on the internet personal information about an

election official or an election official’s immediate family, and

5. the dissemination of personal information posed an imminent

and serious threat to the safety of the election official or the

election official’s immediate family, and

6. the defendant knew or reasonably should have known of the

imminent and serious threat.

[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 unlawfully making available on the internet

personal information about an election official.

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 unlawfully making available

on the internet personal information about an election official.