How many counts of libel for the false statement: “John is at-large from assault charges”?
John may plead his claim(s) either way, but the choice is largely inconsequential to the issue of recovery. There is no such thing of "x dollars per claim of defamatory falsehood", especially where the falsehoods are as intertwined as in the example you outline.
Yes (the libel edition.)
"Morgan and Robin are having an affair and cheating on their respective spouses!"
I hope it's clear enough, on its face, that both Morgan and Robin each have a cause of action.
I hire an engineer to give advice. The advice is:
not what I contracted for - breach of contract
negligent - tort of negligent misstatement
not given with due skill and care - consumer protection warranty breach
defamatory - libel
late - breach of contract again
disclosed to my competition - breach of confidence
The engineer was clearly on a roll.
should I ask the publisher of the statement what facts she relied on in deposition or via interrogatory?
Short answer: Yes, and you do it through deposition, not through written interrogatories.
Long answer: That is one of the most elementary and obvious questions a defamation plaintiff should formulate. But follow-up questions are significantly more ...