Trump v. Rachel Maddow et. al.

What if Trump Proved to the Critics That He’s Rambo

The New York Post did something interesting in its Monday publication. After the Mueller summary was released on the Trump-Russia collusion case, the report found that no member of Trump’s campaign did any collusion with any Russia official even after Russia tried to coerce them to do so, they didn’t take the bait. Since no collusion was found after two years of investigation, the New York Post created an NCAA type basketball bracket of news organizations, cable outlets, media personalities, etc. who kept the barrage of reporting on this story and how they were WRONG!

This also got me to wonder, what if President Trump had a valid case to go after them for giving him unrelenting hell during those two years? Here is what it may look like should he be so inclined to do so:

UNITED STATES DISTRICT COURT

DISTRICT OF COLUMBIA

Donald John Trump

1600 Pennsylvania Avenue, NW

Washington, D.C. 20500,

Plaintiff,

v.

Rachel Maddow,

Ana Navarro,

Donny Deutsch,

Joe Scarborough,

Mika Brzezinski,

Don Lemon,

CNN,

William “Bill” Kristol,

The New York Times,

The Washington Post,

Buzzfeed,

Brian Ross,

MSNBC,

Christopher Cuomo,

Defendants,

Civil Action No. XXX-XX-XXXX

COMPLAINT FOR DEFAMATION

Plaintiff, Donald John Trump (“Plaintiff”) brings this Complaint for defamation against Rachel Maddow, Ann Navarro, Donny Deutsch, Joe Scarborough, Mika Brzezinski, Don Lemon, CNN, Bill Kristol, The New York Times, The Washington Post, Buzzfeed, and Brian Ross (“Defendants”) and states the following:

JURISDICTION AND VENUE

1. This Court enjoys subject matter jurisdiction over this action under 28 U.S.C. § 1332(a)(1) because the Plaintiff and Defendants are citizens of different states and the amount in controversy exceeds $75,000.

2. This Court enjoys personal jurisdiction over the Defendants because the false and defamatory statements made by Defendants were published in the District of Columbia, and the Plaintiff-target of the defamatory statements was and remains a resident of the District of Columbia.

3. This Court enjoys venue under 28 U.S.C. § 1391(a)(2) because all or a substantial portion of the events that gave rise to Plaintiff’s claims transpired in the District of Columbia, including the publication or republication of the defamatory falsehoods and the damage to Plaintiff’s reputation.

PARTIES

4. Plaintiff, Donald John Trump, is the 45th President of The United States and author of several books and articles published by reputable publishing houses. Donald John Trump currently resides in the District of Columbia.

5. The defendant, Rachel Anne Maddow, is an American television host and liberal political commentator. Maddow hosts The Rachel Maddow Show, a nightly television show on MSNBC, and serves as the cable network’s special event co-anchor.

6. The defendant, Ana Violeta Navarro-Cárdenas, is a Nicaraguan-born American Republican strategist and political commentator for various news outlets, including CNN, CNN en Español, ABC News, Telemundo, and The View.

7. The defendant, Donald Jay Deutsch, is an American advertising executive and television personality. He was the host of the CNBC talk show, The Big Idea with Donny Deutsch.

8. The defendant, Charles Joseph Scarborough, is American cable news and talk radio host. He is currently the co-host of Morning Joe on MSNBC with Mika Brzezinski, his wife. He previously hosted Scarborough Country on the same network.

9. The defendant, Mika Emilie Leonia Brzezinski Scarborough, is an American journalist, talk show host, liberal political commentator, and author who currently co-hosts MSNBC’s weekday morning broadcast show Morning Joe and wife of Joe Scarborough.

10. The defendant, Don Carlton Lemon, is an American journalist and author. He is an award-winning news anchor for CNN based in New York City and hosts CNN Tonight.

11. The defendant, Cable News Network, is an American news-based pay television channel owned by WarnerMedia News & Sports, a division of AT&T’s WarnerMedia. CNN was founded in 1980 by American media proprietor Ted Turner as a 24-hour cable news channel.

12. The defendant, William “Bill” Kristol, is an American neoconservative political analyst. He is the founder and former editor-at-large of the defunct political magazine The Weekly Standard and a political commentator on several networks.

13. The defendant, The New York Times, is an American newspaper based in New York City with worldwide influence and readership. Founded in 1851, the paper has won 125 Pulitzer Prizes, more than any other newspaper. The Times is ranked 17th in the world by circulation and 2nd in the U.S.

14. The defendant, The Washington Post, is a major American daily newspaper published in Washington, D.C., with a particular emphasis on national politics and the federal government. It has the largest circulation in the Washington metropolitan area. Its slogan “Democracy Dies in Darkness” began appearing on its masthead in 2017.

15. The defendant, BuzzFeed, Inc., is an American Internet media, news, and entertainment company with a focus on digital media; it is based in New York City. BuzzFeed was founded in 2006 by Jonah Peretti and John S. Johnson III, to focus on tracking viral content.

16. The defendant, Brian Elliot Ross, is an American investigative journalist who served as the Chief Investigative Correspondent for ABC News until 2018. He reported for ABC World News Tonight with David Muir, Nightline, Good Morning America, 20/20, and ABC News Radio. Ross joined ABC News in July 1994 and left in 2018.

17. The defendant, MSNBC, is an American pay television network that provides news coverage and political commentary from NBC News on current events. MSNBC is owned by the NBCUniversal News Group, a unit of the NBCUniversal Television Group division of NBCUniversal.

18. The defendant, Christopher Charles Cuomo, is an American television journalist who currently works at CNN, where he presents Cuomo Prime Time, a regular weeknight CNN show.

STATEMENT OF FACTS

19. In early January 2017, President-elect Trump and President Barack Obama were separately briefed about the Russian interference in the election and on the existence of the Steele dossier by the chiefs of several U.S. intelligence agencies.

20. On January 10, 2017, CNN reported that classified documents presented to Obama and Trump the previous week included allegations that Russian operatives possess “compromising personal and financial information” about Trump. CNN stated that it would not publish specific details on the memos because it had not “independently corroborated the specific allegations.”

21. Following the CNN report, BuzzFeed published a 35-page dossier that it said was the basis of the briefing, including unverified claims that Russian operatives had collected “embarrassing material” involving Trump that could be used to blackmail him. It was not known who provided the dossier to BuzzFeed.

22. According to Adam Schiff, a major portion of the dossier’s content is about Russian efforts to help Trump, and those allegations “turned out to be true” is a false narrative.

23. Trump and Putin have repeatedly denied the allegations, and Trump has labeled the dossier “discredited”, “debunked”, “fictitious”, and “fake news”. David A. Graham, staff writer for The Atlantic, has noted that in spite of Trump’s “mantra that ‘there was no collusion’… it is clear that the Trump campaign and later transition were eager to work with Russia and to keep that secret” is a false narrative.

24. The following is part and parcel of some of the false narrative alleging cultivation, cooperation, and conspiracy with the Trump campaign:

- That “Russian authorities” had cultivated Trump “for at least 5 years”, and that the operation was “supported and directed” by Putin.

- That Trump was a “divisive” and “anti-Establishment” candidate, as well as “a pragmatist with whom they could do business”. That Trump would remain a divisive force even if not elected.

- That a major goal of the Russians in supporting Trump was “to upset the liberal international status quo, including on Ukraine-related sanctions, which was seriously disadvantaging the country.

- That Trump had “so far declined various sweetener real estate business deals”, but had “accepted a regular flow of intelligence from the Kremlin,” notably on his political rivals.

- That there was “a well-developed conspiracy of co-operation between [the Trump campaign] and the Russian leadership,” with information willingly exchanged in both directions. That this co-operation was “sanctioned at highest levels and involving Russian diplomatic staff based in the US.” That the Trump campaign used “moles within DNC and hackers in the US as well as outside in Russia.”

- That Trump associate had established “an intelligence exchange [with the Kremlin] for at least 8 years.” That Trump and his team had delivered “intelligence on the activities, business and otherwise, in the US of leading Russian oligarchs and their families”, as requested by Putin.

- That there was a “Kremlin campaign to aid TRUMP and damage CLINTON”.

- That Trump was susceptible to blackmail due to paying bribes and the existence of “embarrassing material” due to engagement in “perverted sexual acts” and “unorthodox behavior” in Russia, “enough embarrassing material…to be able to blackmail him if they so wished.”

25. Rachel Maddow, a journalist and political commentator, host The Rachel Maddow Show, where the topic of Trump-Russian Collusion has been discussed on her show in the past two years has dominated her broadcast as she has leveled spurious and slanderous allegations against Plaintiff by convicting him in the court of public opinion as these allegations are false and defamatory and exposes Plaintiff to hatred, ridicule, and obloquy.

26. Ana Navarro, a journalist and political commentator, discussed on CNN alleged misconduct of criminal activities during the 2016 election against Plaintiff and thus convicting him in the court of public opinion as these allegations are false and defamatory and expose Plaintiff to hatred, ridicule, and obloquy.

27. Donny Deutsch, a New York City ad executive and political commentator, discussed on MSNBC various slanderous allegations regarding starting a civil war, obstruction of justice and collusion against the Plaintiff and thus convicting him in the court of public opinion as these allegations are false and defamatory and expose Plaintiff to hatred, ridicule, and obloquy.

28. Joe Scarborough, a journalist, and host of MSNBC Morning Joe discussed Trump-Russia collusion and insinuated that Plaintiff had been lying and thus convicting him in the court of public opinion as these allegations are false and defamatory and exposes Plaintiff to hatred, ridicule, and obloquy.

29. Mika Brzezinski, a journalist, and host of MSNBC Morning Joe discussed Trump-Russia collusion and insinuated that Plaintiff was a Russian agent and thus convicting him in the court of public opinion as these allegations are false and defamatory and exposes Plaintiff to hatred, ridicule, and obloquy.

30. Don Lemon, a journalist, and host for CNN continued the false narrative by spreading misinformation of implicating the Plaintiff with the Trump-Russian collusion and conspiracy angle and thus convicting him in the court of public opinion as these allegations are false and defamatory and expose Plaintiff to hatred, ridicule, and obloquy.

31. Brian Ross, a journalist for ABC News, erroneously reported misinformation about the Plaintiff instructing an underling to perform illegal activities by having that under-ling meet with alleged Russian officials as part of the Trump-Russian collusion false narrative and thus convicting him in the court of public opinion as these allegations are false and defamatory and expose Plaintiff to hatred, ridicule, and obloquy.

32. The New York Times, a venerable newspaper organization, printed falsehoods in its paper in a libelous manner that Plaintiff had prompted an F.B.I. Opened Inquiry Into Whether Plaintiff Was Secretly Working on Behalf of Russia implying that Plaintiff was UN-American and a danger to Plaintiff’s country and thus convicting him in the court of public opinion as these allegations are false and defamatory and exposes Plaintiff to hatred, ridicule, and obloquy.

33. The Washington Post, a venerable newspaper organization, continued the falsehoods of misinformation alluding to the narrative that alludes to speculation that the Plaintiff was a conspirator in the Trump-Russia collusion without providing a counter-argument throughout the duration of the allegation and thus convicting him in the court of public opinion as these allegations are false and defamatory and exposes Plaintiff to hatred, ridicule, and obloquy.

34. Buzzfeed, an online media outlet, published the Steele dossier, a fabricated misinformation of non-vetted material of inaccurate facts that initiated the conspiracy theory and led to the creation of the Trump-Russia collusion narrative and thus convicting him in the court of public opinion as these allegations are false and defamatory and exposes Plaintiff to hatred, ridicule and obloquy.

35. MSNBC, a cable media outlet, allowed many of its journalist to continue to narrative of a Trump-Russia collusion that caused irreparable harm to the Plaintiff in performing the duties Plaintiff was elected to do but had to devote a number of hours to answer questions from reporters who were relentless is asking questions on false accusations against the Plaintiff and thus convicting him in the court of public opinion as these allegations are false and defamatory and exposes Plaintiff to hatred, ridicule and obloquy.

36. The Statements individually and collectively are false and were false when made. The Statements are defamatory falsehoods, which Defendants knew or should have known were false when made.

37. Defendants made the Statements with actual malice and wrongful and willful intent to injure Plaintiff. The Statements were made with reckless disregard for their truth or falsity or with knowledge of their falsity and with wanton and willful disregard of the reputation and rights of the Plaintiff.

38. Defendants lacked reasonable grounds for making the Statements and have not offered any retractions for any errors and omissions and apologies to Plaintiff.

COUNT I- DEFAMATION PER SE

39. Plaintiff incorporates by reference into this Count all of the allegations appearing in paragraphs 1–38 appearing in this Complaint.

40. The publication and republication of the Statements proximately caused general and special damages to Plaintiff. Defendants knew, anticipated, foresaw, and intended that the Statements would be read by persons throughout the United States and the world and would damage the reputation of the Plaintiff. The Statements have adversely affected Plaintiff’s scholarly credibility, speaking, writing, and publishing opportunities, book sales, and caused psychological and emotional trauma and suffering.

COUNT II-DEFAMATION PER SE

41. Plaintiff incorporates by reference into this Count all of the allegations appearing in paragraphs 1–40 of this Complaint.

41. The Statements, individually and collectively, referred to herein have caused, are causing, and will cause Plaintiff to suffer an injury to his professional standing, to his reputation and good name; and, they have held and will continue to hold Plaintiff up to public scandal and ridicule. The Statements were calculated to, and do, expose Plaintiff to public scorn, hatred, and ridicule. By such published Statements, Defendants did injure the Plaintiff’s reputation within his professional circles and in the community at large. The publication of the Statements proximately caused general and special damages to the Plaintiff. The Statements have adversely impacted the Plaintiff’s scholarly credibility, and opportunities for writing, teaching, speaking, and book sales. The Statements have damaged Plaintiff’s professional standing in the academic community. The Statements have proximately caused Plaintiff emotional and psychological trauma and suffering which is continuing.

PRAYER FOR RELIEF

42. Plaintiff demands judgment against Defendants, jointly and severally, as follows: (i) for compensatory damages in the amount of $2 million ($2,000,000) on Count I and $2 million ($2,000,000) on Count II; (ii) punitive damages in the amount of $2 million ($2,000,000) on Count I and $2 million ($2,000,000) on Count II; (iii) both pre-judgment and post-judgment interest on both Counts; and, (iv) such other and further relief as this Court finds just and equitable.

JURY TRIAL

WHEREFORE, plaintiff demands judgment against defendants, and each of them, for:

1. Compensatory damages according to proof;

2. Punitive damages;

3. Interest as allowed by law;

4. Costs of suit; and

5. Such other and further relief as this court may deem just and proper.

Plaintiff demands a jury trial.

Respectfully submitted,

/s/

________________________________

Donald J. Trump

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Architectural Designer, Writer, Music Composer, Photographer, Film Editor, Project Manager, Producer, Director

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