NO - Completely wrong!1700. Defamation per se—Essential Factual Elements (Public Officer/Figure and Limited Public Figure)
[Name of plaintiff] claims that [name of defendant] harmed [him/her] by making [one or more of] the following statement(s): [list all claimed per se defamatory statements]. To establish this claim, [name of plaintiff] must prove that all of the following are more likely true than not true:
Liability
1. That [name of defendant] made [one or more of] the statement(s) to [a person/persons] other than [name of plaintiff];
2. That [this person/these people] reasonably understood that the statement(s) [was/were] about [name of plaintiff];
3. [That [this person/these people] reasonably understood the statement(s) to mean that [insert ground(s) for defamation per se, e.g., “[name of plaintiff] had committed a crime”]]; and
4. That the statement(s) [was/were] false.
In addition, [name of plaintiff Steve Saleen] must prove by clear and convincing evidence that [name of defendant- Fred knew the statement(s) [was/were] false or had serious doubts about the truth of the statement(s).
Steve Saleen must prove by clear and convincing evidence that Fred knew the statements were false or had serious doubts about the truth of the statements. The burden of proof is on the plaintiff (Steve Saleen) not the defendant, Fred.
These comments are my opinion. Invest based on your own research and conclusions.
