https://cryptome.org/2020/03/trump-v-nyt-complaint.pdf Defendant The New York Times Company knowingly published false and defamatory statements of and concerning plaintiff Donald J. Trump for President, Inc., claiming it had an "overarching deal" with "Vladimir Putin's oligarchy" to "help in the campaign against Hillary Clinton" in exchange for "a new pro-Russian foreign policy, starting with relief from the Obama administration's burdensome economic sanctions." The Times was well aware when it published these statements that they were not true. The Times' own previous reporting had confirmed the falsity of these statements. But The Times published these statements anyway, knowing them to be false, and knowing it would misinform and mislead its own readers, because of The Times' extreme bias against and animosity toward the Campaign, and The Times' exuberance to improperly influence the presidential election in November 2020.