N.C.P.I.—Crim. 212.10

The defendant has been charged with communicating false and

libelous matter to a newspaper.

For you to find the defendant guilty of this offense, the State must

prove seven things beyond a reasonable doubt:

First, that the defendant (describe means of transmission) (name

newspaper person) that (state libelous statement).

Second, that (name newspaper person) was a(n) [manager] [editor]

[publisher] [reporter] of (name [newspaper] [periodical]).

Third, that the defendant so informed (name newspaper person) for

the purpose of having that information published in (name [newspaper]

[periodical]).

Fourth, that (name [newspaper] [periodical]) published the

information.

Fifth, that (state libelous statement) was libelous of the victim;

that is, was of such a nature as to defame the reputation of the victim.

Sixth, that this information was false.

And Seventh, that the defendant knew or believed that the

information was false or that he was recklessly indifferent as to whether

it was true or false.2

If you find from the evidence beyond a reasonable doubt that on or

about the alleged date, the defendant informed (name newspaper

person), who was a(n) [manager] [editor] [publisher] [reporter] of (name

[newspaper] [periodical]) that (describe libelous statement) for the

purpose of having this information published, and that it was published

by (name newspaper), and that (describe libelous statement) was false

and libelous and was given by the defendant to (name newspaper

person) with knowledge of or belief in its falsity or with reckless disregard

as to its truth or falsity, it would be your duty to return a verdict of

guilty. If you do not so find or have a reasonable doubt as to one or

more of these things, it would be your duty to return a verdict of not

guilty.