SUING THE NEW YORK TIMES
for libel & journalistic fraud
* * *
SUPREME COURT OF THE STATE OF NEW YORK
WESTCHESTER COUNTY -- #19841-05
PLAINTIFFS' March 21, 2006 VERIFIED COMPLAINT
(the 1st full day of Spring)
Exhibit A: “When
the Judge Sledgehammered The Gadfly”,
NYT, November 7, 2004, Westchester
Section, p. 1,
by Marek Fuchs, with plaintiffs' paragraph-by-paragraph
analysis
-- Accompanying primary source documents
substantiating analysis of para. 14:
Attachment #1:
pp 28-35 of the transcript of NYS Senate
Judiciary Committee’s
January 23. 2003
hearing to confirm
Gov Pataki’s “merit selected” appointment of Susan Read
to the NY Court of Appeals
Attachment #2:
Plaintiffs’ written opposition testimony,
NYS Senate Judiciary Committee’s
January 22, 2003
hearing, with documentary
appendix
Attachment #3:
CJA's January 29, 2003 memo to NYT
Editorial Board, enclosing
plaintiffs’
January 29, 2003
letter to NYT Albany Bureau Chief, with Syracuse
Post-
Standard’s
editorial, “A Flawed Process” (1/27/03) and
news article, “DeFrancisco
quiets a critic”
(1/23/03)
Attachment #4:
CJA's February 7, 2003 e-mail/memo to
Eleanor Randolph, NYT
Editorial Board
Attachment #5:
CJA's February 11, 2003 proposed Letter to the
Editor
Attachment #6:
CJA's March 6, 2003 e-mail/memo to Eleanor
Randolph, NYT Editorial
Board
Exhibit B:
CJA's June 11, 2003 memorandum-complaint to NYT
Editorial Board
[referred-to
"Paper Trail" documenting the
corruption of federal judicial
selection/confirmation]
ExhibitC-1:
CJA’s homepage “Paper Trail Documenting the Corruption
of Federal Judicial
Selection/ Confirmation”
as it appeared
on June 10, 2003
Exhibit C-2:
CJA’s homepage, as it appeared on November 6, 2004,
indicating link to “Paper
Trail to Jail”
Exhibit C-3:
CJA’s “Paper Trail Documenting the Corruption of Federal
Judicial
Selection/Confirmation & the ‘Disruption of
Congress’ Case it Spawned” as it appeared throughout
Elena Sassower’s six-month
incarceration from June 28,
2004 to December 23, 2004
Exhibit D: CJA's June 19, 2003 letter to NYT
Assistant Managing
Editor Allan Siegal
Exhibit E:
CJA’s website page, “Press Suppression-The New York
Times”, as it
appeared from June 28, 2004,
without
change through December 23, 2004
Exhibit F:
CJA's August 26, 2003 letter to Outgoing NYT
Washington Bureau
Chief – Incoming Managing
Editor for
Newsgathering Jill Abramson
Exhibit G:
CJA's September 25, 2003 letter to NYT Executive
Editor Bill Keller
Exhibit H:
CJA’s October 13, 2003 letter to NYT Executive Editor
Keller
Exhibit I: CJA's November 1, 2003 letter to NYT Executive Editor
Keller
Exhibit J-1:
CJA's December 1, 2003 letter to NYT Public Editor
Daniel Okrent
Exhibit J-2:
CJA's December 24, 2003 e-mail to NYT Public Editor
Okrent
Exhibit J-3:
Automated December 24, 2003 e-mail acknowledgment
from NYT Public Editor
Okrent
Exhibit J-4: December 24, 2003 e-mail from Arthur Bovino,
Office of NYT Public Editor
Exhibit K-1:
CJA's June 16, 2003 memorandum to Ralph Nader,
Public Citizen, Common
Cause
Exhibit K-2: CJA's homepage (as
of May 9, 2004)
Exhibit K-3: CJA's homepage
(from May 22, 2004 to sometime after
June 28, 2004)
Exhibit L-1: CJA's May 11, 2004 letter to NYT reporter Raymond
Hernandez
Exhibit L-2:
Hernandez’ May 11, 2004 e-mail
Exhibit L-3:
CJA's May 11, 2004 fax note to Hernandez
Exhibit L-4: CJA's May 17, 2004 e-mail to Hernandez
Exhibit M: CJA's May 24, 2004 memorandum to Gerry Mulaney,
NYT Deputy Metro
Editor for Politics
Exhibit N:
CJA's June 17, 2004 memorandum-complaint to
Public Editor Okrent
Exhibit O-1: CJA's June 17, 2004 e-mail to Public Editor Okrent
(3:21 p.m.)
Exhibit O-2:
June 17, 2004 automated acknowledgment (3:28 p.m.)
Exhibit O-3:
Arthur Bovino's June 17, 2004 e-mail (3:34 p.m.)
Exhibit O-4:
CJA's June 17, 2004 e-mail to Bovino (4:29 p.m.)
Exhibit O-5:
Arthur Bovino's June 17, 2004 e-mail (4:43 p.m.)
Exhibit O-6:
CJA's June 17, 2004 e-mail to Bovino (5:56 p.m.)
Exhibit O-7:
Arthur Bovino's June 17, 2004 e-mail (10:12 p.m.)
Exhibit O-8:
CJA's June 18, 2004 e-mail to Bovino (2:27 p.m.)
Exhibit O-9:
CJA’s June 20, 2004 e-mail (4:22 p.m.)
Exhibit O-10:
Daniel Okrent’s June 21, 2004 e-mail (11:16 a.m.)
Exhibit O-11:
CJA's June 22, 2004 e-mail to Okrent (9:32 a.m.)
Exhibit O-12:
Arthur Bovino's June 22, 2004 e-mail (9:47 a.m.)
Exhibit O-13:
CJA's June 22, 2004 e-mail to Bovino (10:48 a.m.)
Exhibit O-14:
Arthur Bovino's June 22, 2004 e-mail (11:14 a.m.)
Exhibit O-15:
CJA's June 22, 2004 e-mail to Arthur (3:07 p.m.)
Exhibit P:
CJA's June 25, 2004 e-mail (cc) to Public Editor Okrent,
Gerry Mulaney,
Philip Taubman,
Raymond Hernandez,
Neil Lewis
Exhibit Q:
CJA's July 29, 2005 letter to NYT Executive Editor Bill
Keller
Exhibit R-1:
CJA's August 16, 2005 memorandum to NYT recipients
of July 29, 2005
letter
Exhibit R-2:
CJA's March 26, 2003 written statement of opposition to
the nominations of
Judge Wesley
& P. Kevin Castel, Esq.
Exhibit S-1: CJA's September 26, 2005 letter to NYT Public
Editor
Byron Calame
Exhibit S-2:
Public Editor Calame’s September 30, 2005 e-mail
Exhibit T-1:
CJA's November 30, 2005 letter to NYT Co. Assistant
General
Counsel George Freeman
Exhibit
T-2: George Freeman’s December 2, 2005 letter, with
envelope
postmarked December 6, 2005
Exhibit T-3:
Plaintiffs’ December 14, 2005 letter to George Freeman
Exhibit T-4:
Plaintiffs’ December 22, 2005 letter to George Freeman
Exhibit T-5 :
Plaintiffs’ December 30, 2005 letter to NYT Co. Senior
Vice President & General
Counsel
Solomon B. Watson, IV
Exhibit T-6:
George Freeman’s January 3, 2006 letter
Exhibit T-7: CJA's January 6, 2006 letter to Solomon B. Watson,
IV
Exhibit T-8 CJA's January 12, 2006 letter to Solomon B. Watson,
IV,
with
CJA's November 1, 2005 and November 4, 2005 ltrs
Exhibit T-9:
Senior Counsel David McCraw’s January 12, 2006 e-mail
Exhibit T-10:
George Freeman’s January 10, 2006 letter
Exhibit T-11: CJA's January 13, 2006 letter to David McCraw
Exhibit T-12:
David McCraw’s January 13, 2006 e-mail
Exhibit T-13: CJA's January 16, 2006 letter to David McCraw
Exhibit T-14:
David McCraw’s January 17, 2006 e-mail
Exhibit T-15: CJA's January 19, 2006 letter to David McCraw
Exhibit T-16: CJA's January 24, 2006 letter to NYT Co. Senior Vice
President & Chief Legal Officer
Solomon B. Watson, IV
Exhibit T-17: CJA's January 27, 2006 letter to Solomon B. Watson,
IV
Exhibit T-18:
CJA's January 30, 2006 letter to NYT Co., Secretary,
Corporate Governance
Officer & Senior
Counsel Rhonda
L. Brauer
Exhibit T-19:
CJA's February 3, 2006 memo to all individualdefendants
except Okrent
Exhibit T-20: CJA's February 13, 2006 letter to Edward Bohan, Legal
Assistant
Exhibit T-21:
CJA's February 14, 2006 letter to Solomon B. Watson, IV
and Rhonda Brauer
Exhibit T-22: CJA's March 2, 2006 letter to Edward Bohan
