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SUPREME
COURT
COUNTY
OF
OF THE
STATE
NEW YORK
OF
NEW YORK
--------------------------------------------------------------------------X
MICHAEL
COHEN,
Plaintiff,
COMPLAINT
-against-
KEN and
BEN
INC.,
BUZZFEED,
BENSINGER,
MARK
SMITH
MIRIAM
Index
EI
No.:
DER,
SCHOOFS,
Defendants. --------------------------------------------------------------------------
MICHAEL
Plaintiff,
Gerstman
Schwartz
KEN
SMITH,
sets
forth
and
and
alleges
COHEN
(hereinafter
"Plaintiff' "Plaintiff"),
LLP,
complaining
of
Malito,
MIRIAM
BENSINGER,
X
This
statements
about
"Exhibit
2017
A"),
(annexed
"These
Bensinger
the
and
decision
Ben
2.
and
and
"[t]he
BUZZFEED,
SCHOOFS
attorneys,
BEN
INC., "Defendants" "Defendants"),
(hereinafter
STATEMENT
Allege
edited
Trump
by
publish
defamation
entirety
Has
the
Ties
Article
to
was
Russia"
Miriam
Elder
and
Dossier
Inc.
"Article" "Article")
(the
Mark
and
was
by
(annexed
an article
as
10,
entitled
Defendant
by
On information
BuzzFeed's
hereto
on January
with
written
Schoofs.
made
inflammatory
("BuzzFeed")
together
published
highly
"Dossier,"
the
BuzzFeed,
Dossier
and
damaging,
in
contained
Defendant
The
Deep
Defendants
were
by
B").
on false,
based
statements
as "Exhibit
and
Ken
belief,
Editor-in-Chief,
Smith.
BuzzFeed
potentially
that
in its
hereto
for
The
published
to
Defendant
is an action
Plaintiff.
Reports
Defendants
his
as follows:
PRELIMINARY
1.
MARK
and
ELDER,
the
through
and
by
unverifiable
allegations
admitted
in
allegations
are
the
that
Article
of
Dossier
the
between
contact
unverified."
Even
Trump
though
specific,
"include[d]
aides
Defendant
and
Russian
BuzzFeed
unverified operatives"
expressly
1
This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i)) which, at the time of its printout from the court system's electronic website, had not yet been reviewed and approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject filings for various reasons, readers should be aware that documents bearing this legend may not have been 1 of accepted for filing by the County Clerk.
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INDEX NO. UNASSIGNED
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NYSCEF DOC. NO. 2
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acknowledged
the
unverified
Defendant
BuzzFeed
attempting
to determine
personal
and
opportunities
about
him
published
the
Plaintiff
3.
(and
potentially
the
of
veracity
professional
reputation,
that
from
resulted
published
these
an award
seeks
Dossier
un-redacted
of
the
business
false
blatantly
the
Plaintiff
and
compensatory
current
and
with
reports
of
nature
unverifiable)
Dossier's
Article
allegations, -
anyway
without
himself.
punitive
for
damages
of
statements
defamatory
harm
the
impairment
and
interests,
and
the
and
to his
business
implications
Defendants.
by
PARTIES
Plaintiff
4.
New
Michael
Cohen
is an attorney
for
Donald
and
Trump
of New
resident
York,
York.
5.
Defendant
in
headquartered
media
company
BuzzFeed,
New
York
City.
news
delivering
a Delaware
Inc.,
BuzzFeed
and
itself
describes
entertainment
is a global
corporation,
as "the
of
to hundreds
organization
news
digital
independent
leading
of
millions
people
around
the
world."
6.
He
is
Editor-in-Chief
the
has
and
7.
are
while
-
California
Editor
World
to
the
Ken
Bensinger
based
the
News
in New
author
Miriam
Investigations
York
under
politics,
growing
and
information
BuzzFeed
include
Defendants
and
on
Smith,
of
Defendant
8.
and
grown
entertainment
Angeles,
Ben
Defendant
whose
business,
site's
leadership,
to
reporter
for
York.
its
BuzzFeed,
longform
unique
monthly
New
Brooklyn,
according
reporting,
200M
investigative
in
resides
belief,
investigative
to over
traffic
is an
of the
Elder
and
journalism,
visitors."
BuzzFeed
based
in
Los
Article.
and
Editor.
Mark
Schoofs
On information
are,
BuzzFeed's
respectively,
and
belief,
they
edited
the
News
Article
City.
This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i)) which, at the time of its printout from the court system's electronic website, had not yet been reviewed and approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject filings for various reasons, readers should be aware that documents bearing this legend may not have been 2 of accepted for filing by the County Clerk.
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On
9.
of
employees
control
and
information
BuzzFeed,
and
in that
and,
Defendants
belief,
their
capacity,
On January
10.
Reports
Allege
headline
consist
political
opponent
of
agent,"
pertain
of
gained
been
publish,
even
investigator,
debate
and
that
compilation.
-
Schoofs
are
to BuzzFeed's
in
spite
not
the
intended
Dossier's
Additionally,
-
of
headline
in
to
British
these
the
for
"prepared
("CIRs"),
Four
Dossier.
the
referred
a former
be
facts
a
intelligence
&
134-136
CIRs,
allegations
written
memos
that
Russian
the
Donald
"specific,
including
aides
Trump
in
the
"explosive."
that
also
that
bore
information
and
its
[D]ossier
but
the
Dossier
discourse
multiple
and
belief,
in
"reporters
was
for
Trump
and
operatives."
Russian
have
over
not
the
or
nevertheless
the
secret
or to make
hallmarks
Defendant
of
its
of
irresponsible
was
B.
have them,"
the
an argument
and
Exhibit
Europe
made
BuzzFeed
years
falsified
product
has
potentially
See
US and
verified
a period
government
unverified,
Smith
Defendant
of public
to be part
on
of
him,"
awareness
content
collection
President-elect
[then]
acknowledged
are
his
unverified
between
alleged
of
but
on
BuzzFeed
allegations
the
to
with
Article
"Reports"
2016
is understood
as "a
assisting
contact
various
Dossier's
private
and
is subject
the
The
Reports
Dossier
the
information
investigating
the
and
B.
and
Defendant
Intelligence
comprise
published
Russia."
To
together
describes
of
Ties
Deep
who
"explosive
allegations
that
conduct
BuzzFeed
a person
Exhibit
supporting
12.
to
Article
compromising
unverifiable
and
See
containing
cultivating,
by
which
pages,
The
Has
Company
Trump
months"
been
professional
Elder
ALLEGATIONS
Defendant
2017,
seventeen
to Plaintiff.
11.
10,
Trump
of
35
totaling
166,
Bensinger,
supervision.
FACTUAL
"These
Smith,
decision
a secretive
in a public
collection
aware
that
This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i)) which, at the time of its printout from the court system's electronic website, had not yet been reviewed and approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject filings for various reasons, readers should be aware that documents bearing this legend may not have been 3 of accepted for filing by the County Clerk.
10
INDEX NO. UNASSIGNED
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NYSCEF DOC. NO. 2
there
RECEIVED NYSCEF: 01/09/2018
were
organization
In
world"
- with
readers
in every
while
increases
Exhibit
and
See
Exhibit
these
of
that
reports
and
that
did
so
other
no
news
B.
BuzzFeed
content,
readership
awareness
to
of
"hundreds
it would
of
millions
then
be republished
as having
been
in
a manner
people
that
around
to millions
the
more
society.
refers
that
"[t]he
the
likelihood
allegations
that
officials,
unverified."
are
persons
search
The
in
interested
Dossier
the
Plaintiff
to find
in
named
Article,
by
what
despite
the
not
print
it says
Dossier,
referring
but
institutions,
out
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explicitly
(including
financial
authorities,
regulatory
would
Plaintiff
to
about
limited
and
online
Plaintiff.
See
B.
15.
whether
Defendants
the
defamatory
them
published
with
defamatory
fashion.
importance
of
in
section,
"Summary"
the
report
relationship."
Under
with
the
this
report,
Russian
again
See
a leading
Exhibit
Plaintiff
government
is
of this
COHEN
states
&
that
166
were
they
2016,
section
father
CIRs
134-136
20,
Michael
her
and
CIRs
October
dated
and
Dossier
as to whether
disregard
lawyer,
descent
campaign/Kremlin
relationship
accusations
In the
"Detail"
17.
the
134,
TRUMP's
is of Russian
published
reckless
CIR
16.
in the
claimed
journalists)
privy
unverified
specifically
intelligence
media
Dossier's
global
Article
acknowledging
news
of
made
Dossier.
additional
stratum
to government
wife
BuzzFeed's
The
Plaintiff,
the
BuzzFeed's
14.
outlets
the
publishing
it to reach
allowed
media
to publish
decided
13.
to
other
numerous
the
report,
in covert
Plaintiff
report
were
to
not
know
and/or
true
insider
with
relationship
in
a "key
Russia.
Moscow."
role
Plaintiff
discuss
"Kremlin
it states:
played
did
they
or false.
true
first
that
Plaintiff
about
developer
property
fact
highlights
COHEN's
Further
in the
secret
in
down,
TRUMP
A.
is alleged
stemming
to have
from
an inappropriate
his
wife's
and
familial
possibly
relations
criminal
with
a
This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i)) which, at the time of its printout from the court system's electronic website, had not yet been reviewed and approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject filings for various reasons, readers should be aware that documents bearing this legend may not have been 4 of accepted for filing by the County Clerk.
10
INDEX NO. UNASSIGNED
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NYSCEF DOC. NO. 2
Russian
RECEIVED NYSCEF: 01/09/2018
with
relationship
vacation
home
Ukraine
region
Russia.
the
of
context
manipulation
reputation
in his
COHEN
IN
section,
it
MANAFORT of this
important
as candidate
engaged
goal."
in
in a cover
TRUMP's
19.
Plaintiff
The
"met
the
and
that
election.
born
in the
has
never
been
she
is
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in
was
even
vital
also
own
Russia
in
the
harmed
a
of
accused
being
with
was
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developer
wife
ago;
Plaintiff
any
not
relationship
and,
alleged
Plaintiff's
Russia
goes
secretly
explains
this
liaison
limitation
which
grew
then
2016,
operation exposed."
how
Plaintiff's
Russian
in
further,
first
between
the
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following
Mr.
Manafort's
attempt
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role
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that
Plaintiff
to prevent
scandal
of
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in
in
Plaintiff
that
stating
York
tycoon's
departure
became
the
title,
"Summary"
up
EU
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allegation
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to
trying
officials
relationship
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on to describe
with
Kremlin
meets
OF TRUMP
KREMLIN."
in
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beginning
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Russians
leadership,"
manager
defamatory,
IMPORTANT
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with
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secret
damage
with
report
unlawful
have
does
Plaintiff
obvious:
implies
THE
section
Russian
campaign
relationship
years
(40)
is similarly
LIAISON
PAGE
of
ongoing
and
up
property
Plaintiff's
forty
allegedly
19, 2016,
"engaged
"Detail"
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Trump's
over
report
ELECTION:
Plaintiff
"the
States
presidential
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exposure
campaign
[Trump's]
that
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is
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not
does
father-in-law
there.
allegations
the
not
is
Plaintiff
true.
Plaintiff's
fact,
Trump's
SECRET
that
the
are
as an attorney-at-law.
CAMPAIGN'S
states
by
2016
dated
135,
United
Dossier,
PRESIDENTIAL
"RUSSIA/US
pursuit
the
profession
CIR
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of
the
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been
in candidate
of
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father-in-law
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to the
caused
role
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immigrated
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unlawful
was
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to
nor
Sochi,
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maintaining
in
in
officials
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only
of
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Russian
he has
Moscow;
to
developer.
property
full
"heavily
details
of
A.
in attempting
Administration
a cover-up,
(PA)
finding
Legal
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This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i)) which, at the time of its printout from the court system's electronic website, had not yet been reviewed and approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject filings for various reasons, readers should be aware that documents bearing this legend may not have been 5 of accepted for filing by the County Clerk.
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Department
Manafort's
connections
figures
leadership
and
make
sure
no
20.
Russia
had
admits
that
for
this
Clearly,
linked
to
through
been
has
as to whether
disregard
22.
the
unlawful
Plaintiff's insider"
Republic."
alleged
indicated
In the
to
in his
CIR
23.
that
linked
damaged
caused
with
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information
in
of
these
with
of
and
conspiracy
the
and
Trump
individuals
from
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while
of
exact
personally
that
and
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baseless
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campaign
conceal
to
the
PA
of
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again
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of
locations
Plaintiff
clear:
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identities
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of truth.
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for
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the
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knowledge
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met
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candidate
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or
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used
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Mr.
Russian
under
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officials.
any
rigging
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Russian
the
campaign
generated
"to
relationship
as Plaintiff
secretly
he was
the
are true
this
secret
proven."
or
find
officials
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this
time
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and
acts,
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136,
meetings
to
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communications
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met
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order
objective"
2016,
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COHEN
whom
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established
that
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former
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for
of these
insider
"the
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TRUMP
the
Ukraine
be fully
since
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and
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reckless
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officials
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in
officials
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136
on
followed-up
of
August
2016
"reported
contact/s
also
that
states
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by
took
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report
previous
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finding
place
in
Kosachev,
as
to
a "Kremlin
Prague,
the
Czech
Head
of
This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i)) which, at the time of its printout from the court system's electronic website, had not yet been reviewed and approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject filings for various reasons, readers should be aware that documents bearing this legend may not have been 6 of accepted for filing by the County Clerk.
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NYSCEF DOC. NO. 2
the
RECEIVED NYSCEF: 01/09/2018
Foreign
Relations
deniable'
as a "'plausibly COHEN."
In
have
suspicion.
24.
let
he
have
reputation
that
took
they
with
CIR
of
from
won
the
with
organization,
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Russian
Russian
the
involved
meeting/s
between
and
report
made
for
with
the
presidency." Namely,
Plaintiff
Trump
officials
may
government
from
"either
in
against
up these team
more
agreed
in particular
alleged
was
plan
have
with
met
to Prague,
Czech
Mr.
him
to
to harm
the
nor
Kosachev,
office.
served
only
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by
the
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Plaintiff's
campaign's
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of the
on how had
of
in
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and
or
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first
first
by
when
week
of
finding:
payments under
Europe
campaign
136
changes
the
meeting(s),
cash
deniable
and
135
August
Prague
worked
operations
CIRs
colleagues
week
last
topic
from
up
various
Moscow's
secret
generally.
to "contingency
what
been
organization's
linking
CLINTON
the
covering
TRUMP
the
the
who
have
followed
meeting(s)
hackers
not
even
election.
the
questions
[of] to
never
and
by
2016,
describes
of having
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to
in truth
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to
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presidential
the
2016
direction
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operation,
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of
contingencies
[hacking]
Plaintiff
could
a Russian
damaged
comprised be
in
December
the
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the
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relationship
to protect
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any
accompanied
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liaison
have
August
to
and
without
dated
Additionally,
Plaintiff
August
the
Russian
the
in order
true.
officials
thus
September."
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for
between
office
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meddling
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were
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cover"
a
in
participated
a
figure,"
Duma
leading
that
meetings
Prague
Kremlin
are
Plaintiff
place
these
have
claimed
as
allegations
August
acts
25.
stating
these
attorney
unlawful
alleged
in
met
as an
is
a "Pro-Putin
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statements
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that
organization's
of
alone
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used
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officials
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Republic,
could
was
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who
section,
in this
occurred
and
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the
Kremlin
and
Russia
facilitator"
"Rossotrudnichestvo,"
campaign
for
Committee
plans
to be done
was
to
ensure
in the
that
for
various
event
"all
that
cash
scenarios
to protect
Hillary
CLINTON
payments
owed
[to
This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i)) which, at the time of its printout from the court system's electronic website, had not yet been reviewed and approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject filings for various reasons, readers should be aware that documents bearing this legend may not have been 7 of accepted for filing by the County Clerk.
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were
hackers]
down/able
made
to go
with
Russian
ensure
that
meeting
how
to
also
implicates
how
to recompense
damage
report
describes
altered
global
institutional
By
of
therefore
allegations
which,
to
of
Defendants' Defendants
Plaintiff,
House
Senate
was
it
by
later
accusations
are
in
true
of
an illegal
harmed
severely
his
he
the
on
report
The
helped
determine
even
been
slightest.
and
only
plans
never
has
destructive
part
stood
not
formulating
that
finding
of
uncovered.
Plaintiff
indescribably
lightly,
a reckless
Plaintiff
Committee
subjected
on
28.
set forth
Plaintiff
repeats,
Tort
(As
against
reiterates,
two
Intelligence
(annexed
Intentional
it
at least
on
Intelligence
the
In particular,
to
Committee
of
whether
damages.
was
Select
of
disregard
reputational
and
Permanent
Select
publication
CAUSE
though
the
Plaintiff
and
hacking
be
were
A.
accused
aforementioned,
of
operators
Exhibit
not
would
election
a significant
put
illegal
the
U.S.
As
See
Defendants
and
the
none
as overseeing
cause
with
published
concerning
the
about
continue
hacking
false
166
other
and
And
to
the
irreversible.
The
operation
that
personal,
professional,
permanently
and
reputation.
financial
the
CIR
responsible.
and
Plaintiff
significant
by
the
traces."
their
knowing
could
hackers
these
by
politics
27.
and/or
the
Republic,
caused
but
operation
in
of
publishing
officials,
Plaintiff
Czech
Prague,
their
this
to cover
cyber
that
and
discreetly
to ground
effectively
Through
26.
and
quickly
OF -
was
by
or
true
they
Plaintiff
false,
the
publishing
knew
fallacious
Congressional
separate
(annexed
as "Exhibit
hereto
to
be
false
sustained
reports
investigations
as "Exhibit
C")
allegation
above
and
D").
ACTION
Defamation all
and
hereto
which
Dossier,
Per
Se
Defendants)
re-alleges
each
and
every
as
herein.
This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i)) which, at the time of its printout from the court system's electronic website, had not yet been reviewed and approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject filings for various reasons, readers should be aware that documents bearing this legend may not have been 8 of accepted for filing by the County Clerk.
10
INDEX NO. UNASSIGNED
CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.)
NYSCEF DOC. NO. 2
RECEIVED NYSCEF: 01/09/2018
In order
29.
of
statement
a false
plaintiff
is a public
malice,
figure,
that
meaning
disregard
the
truth
to its
30.
was
published
he must
also
who
party
for
to
a third
that
allege
published
and
party,
the
defamatory
statement
the
a plaintiff
defamation,
allege
resulting
damages.
statement
was
it was
knew
must
the
When
with
made
or acted
false
making
with
the
actual
reckless
or falsity.
Further,
a cause
of
in his
trade,
a plaintiff
injure
utterly
which
of action
a cause
to state
action
for
defamation
per
or profession
business,
when
se is stated
or accuse
him
the
of
false
statements
a serious
committing
crime.
Through
31.
published
to a worldwide
32.
in
the
to
Prague,
Czech
crimes
committed
been
allegedly
rig
continued
and
33.
to sustain,
due
in
cover
serious
it up
reason
campaign
later
of the
and
crimes
Carter
and
accused
JURY
Plaintiff
hereby
demands
a trial
of Defendants,
how
to
off
the
ensure
that
the
Russian
in
officials
to
the
cover-up
hackers
to undermine
by jury
of
Plaintiff
in particular
damages,
been
(1)
pay
the
Kremlin
decide:
government
to
and
role
who
had
candidate
operation
hacking
if necessary.
acts
reputational
how
Russian
how
(3)
discovery,
foregoing
he has
the
to
a key
playing
team
with
meeting
2016
(2)
of
campaign
through
Defendants
166,
Plaintiff.
Plaintiff
accusing
Page;
and
campaign;
from
financial
serious
September
&
134-136
concerning
presidential
and/or
Trump
presidential
statements
Trump's
and
CIRs
statements
election
August
and
defamatory
presidential
Manafort
the
by
Dossier
the
published
U.S.
Paul
by
By
to the
2016
and
candidate
by
Republic,
Clinton's
Hillary
the
paid
false
Defendants
formed
conspiracy
of
posting
public
Namely,
government
and
their
sustained,
to his
profession
and
will
continue
as an attorney
committing.
DEMAND as to all
issues
so triable.
This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i)) which, at the time of its printout from the court system's electronic website, had not yet been reviewed and approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject filings for various reasons, readers should be aware that documents bearing this legend may not have been 9 of accepted for filing by the County Clerk.
10
INDEX NO. UNASSIGNED
CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.)
NYSCEF DOC. NO. 2
RECEIVED NYSCEF: 01/09/2018
PRAYER upon
WHEREFORE, requests
respectfully
A.
that
Grant
this
all
of
the
FOR
RELIEF
facts
and
herein
circumstances
Plaintiff
alleged,
Court:
judgment
against
on
Defendants
each
and
of
cause
every
action
alleged
herein;
B.
Grant
an order
together
with
awarding
interest
attorneys'
punitive
fees,
C.
Dated:
recovered
by
Grant
such
any
January
9, 2018
Garden
City,
New
and
law
Plaintiff
damages
the
and
relief
to the
above
as the
an amount
disbursements
as well
damages,
pursuant
further
costs
in
Court
ofthis
other
as any
causes
deems
to be
of
plus
action,
damages
reasonable
permitted
to
be
and
action;
just,
at trial,
determined
and
proper,
equitable.
York
GERSTMAN /s/
SCHWARTZ
David
&
MALITO,
Suite
200
LLP
Schwartz
M.
By: David
M.
Garden Tel.
No.:
Esq.
Schwartz,
Franklin
1399
City, (516)
Avenue,
New 880
York -
11530 8170
1
This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i)) which, at the time of its printout from the court system's electronic website, had not yet been reviewed and approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject filings for various reasons, readers should be aware that documents bearing this legend may not have been 10 of 10 accepted for filing by the County Clerk.
