23.10(2) [1980 New] Verdict Directing-Slander-Plaintiff a Public Official or Public Figure

Instruction No 1 23.10(2) [1980 New] Verdict Directing--Slander--Plaintiff a Public Official or Public Figure Your verdict must be for plaintiff if you believe: First, defendant stated (here insert the statement claimed to be slanderous 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 the 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 heard by (here insert name of person or persons other than plaintiff who heard the statement ), 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 ) ].