23.06(2) [1980 New] Verdict Directing-Libel-Plaintiff a Public Official or Public Figure

Instruction No 1 23.06(2) [1980 New] Verdict Directing--Libel--Plaintiff a Public Official or Public Figure Your verdict must be for plaintiff if you believe: First, defendant (describe act such as "published a newspaper article" ) containing the statement (here insert the statement claimed to be libelous such as "plaintiff was a convicted felon" ), and Second, such statement was false, and Third, defendant (describe the act of publication such as "published such statement", "wrote such letter", etc.) either: with knowledge that it was false, or with reckless disregard for whether it was true or false at a time when defendant had serious doubt as to whether it was true, and Fourth, such statement tended to [expose plaintiff to (select appropriate term or terms such as "hatred", "contempt" or "ridicule" ) ] [or] [deprive the plaintiff of the benefit of public confidence and social associations], and Fifth, such statement was read by (here insert name of person or persons other than plaintiff or the appropriate generic term such as "the public" ), and Sixth, plaintiff's reputation was thereby damaged. * [unless you believe plaintiff is not entitled to recover by reason of Instruction Number (here insert number of affirmative defense instruction ) ].