4. It came as no surprise when, shortly before the Election, the newspaper
published, on the front page, highlighted in a location never seen before, its deranged
endorsement of Kamala Harris with the hyperbolic opening line “[i]t is hard to
imagine a candidate more unworthy to serve as president of the United States than
Donald Trump.”
...
6. The subject matter of this action—a malicious, defamatory, and
disparaging book written by two of its reporters and three false, malicious,
defamatory, and disparaging articles, all carefully crafted by Defendants, with actual
malice, calculated to inflict maximum damage upon President Trump, and all
published during the height of a Presidential Election that became the most
consequential in American history—represent a new journalistic low for the
hopelessly compromised and tarnished “Gray Lady.” Defendants’ pre-election goal
was to kill three birds with one stone: (a) damage President Trump’s hard-earned
and world-renowned reputation for business success, (b) in the process, sabotage his
2024 candidacy for President of the United States, and (c) prejudice judges and juries
in the unlawful cases brought against President Trump, his family, and his businesses
by his political opponents for purposes of election interference. With President
Trump having won the Presidency, Defendants’ goals remain similar and unlawful: tarnish his legacy of achievement, destroy his reputation as a successful
businessman, and subject him to humiliation and ridicule.