In order to establish a claim of libel, the plaintiff must prove the following elements:
That the defendant made a false and defamatory written or printed communication concerning the plaintiff.
- That the communication was published to a third party;
- That the defendant either knew the communication was false and that it defamed the plaintiff [,] [or] acted in reckless disregard of these matters [, or acted negligently in failing to ascertain them]; and,
- That the publication of the communication was a [proximate] [legal] cause of special damages to the plaintiff [or that the defamatory communication constituted libel per se].
NEV. J.I. 8.04