CJI-Civ. 22:4

The plaintiff, (name), claims that the defendant, (name), (published) (or) (caused to

be published) the following statement(s):

(Insert the text of the statement[s] determined by the court to be defamatory.)

For the plaintiff to recover from the defendant on (insert applicable pronoun) claim

for (libel) (slander), you must find by a preponderance of the evidence that the defendant

(published) (or) (caused to be published) the statement(s) set forth above in the same or

substantially similar words.

If you find that this has not been proved, then your verdict must be for the

defendant.

On the other hand, if you find that this has been proved, (then your verdict must be

for the plaintiff) (then you must consider the defendant’s affirmative defense(s) of [insert

any affirmative defense that would be a complete defense to the plaintiff’s claim]).

If you find that (this affirmative defense has) (any one or more of these affirmative

defenses have) been proved by a preponderance of the evidence, then your verdict must be

for the defendant.

(In determining whether the affirmative defense of privilege [describe privilege] has

been proved, you must also determine whether the defendant abused that privilege as

explained in Instruction No. [insert instruction number that corresponds to 22:18].)

However, if you find that (this affirmative defense has not) (none of these

affirmative defenses have) been proved, then your verdict must be for the plaintiff.