From the Criticism in Wilkins v. Versant Media Group. Inc. (M.D. Tenn.), filed Friday:
This defamation lawsuit is about MS Now (previously, MSNBC) utilizing sham “nameless” sources to push knowingly or recklessly false allegations that Alexis Wilkins, by her relationship with FBI Director Kash Patel, abused FBI sources. Defendants are, in fact, free to touch upon the management of the FBI and its allocation of sources, whether or not positively or negatively. They don’t seem to be, nonetheless, entitled to lie about it.
Defendants falsely asserted that Ms. Wilkins demanded, and Director Patel ordered, that federal brokers assigned to her safety element—which didn’t even exist on the time—escort an intoxicated buddy residence after a “evening of partying.” They falsely portrayed Ms. Wilkins as being intoxicated even understanding that she doesn’t drink. Defendants presumed they might get away with this fiction by citing to “nameless sources,” disingenuously claiming “nonpublic” and “inside” information. This was hogwash and so they knew it. Journalists can’t keep away from accountability by hiding behind fabricated “nameless” sources. This lawsuit seeks to carry accountability for Defendants’ egregious lies….
On December 5, 2025, Defendant, MS Now, revealed an article, written by its workers, Defendants Carol Leonnig and Ken Dilanian, titled, “Kash Patel ordered FBI element to offer girlfriend’s pal a carry residence: sources” …. Within the Article, Defendants wrote:
FBI Director Kash Patel has—on multiple event—ordered that the safety element defending his girlfriend escort one among her allegedly inebriated buddies residence after an evening of partying in Nashville, in line with three folks with information of the incidents.
Patel’s girlfriend, Alexis Wilkins, requested FBI brokers on her safety crew a minimum of two instances, together with as soon as this spring, to drive her buddy residence, and brokers objected to diverting from their project, stated the sources, who have been granted anonymity to debate nonpublic issues. However Patel insisted they do as Wilkins requested and in a single case referred to as the chief of Wilkins’ safety element and yelled at him to take action.
That is solely false. Director Patel has by no means ordered any FBI agent or member of Ms. Wilkins’ safety element to escort any of Ms. Wilkins’ buddies residence—inebriated or in any other case—nor did Ms. Wilkins ask any of them to take action. Not solely did these supposed calls for/orders by no means happen, however all the state of affairs is fabricated. No FBI brokers have ever escorted any of Ms. Wilkins’ buddies residence.
Defendants claimed within the Article that the substance of their defamatory allegations supposedly occurred in Spring 2025. Notably, Ms. Wilkins didn’t have a safety element at the moment. Defendants have been conscious of this. Defendants had beforehand revealed, on November 17, 2025, an total article about Ms. Wilkins’ safety element. Defendants have been the primary to interrupt that story as Ms. Wilkins had solely then been not too long ago assigned a element, mandatory resulting from credible dying threats made towards her….
On December 2, 2025—three days previous to publication of the Article at difficulty on this case—Defendant Dilanian reached out to FBI spokesman, Ben Williamson, to acquire touch upon the accusation that Ms. Wilkins’ element had been diverted to escort her buddies residence. Defendants grossly misrepresented and diminished the FBI’s response within the Article, writing:
FBI spokesperson Ben Williamson didn’t reply questions on a number of inside accounts of Wilkins’ element being diverted, however broadly denied such occasions befell.
“That is made up and didn’t occur,” Williamson stated.
{Since its authentic publication, Defendants have stealth-edited the Article, with none acknowledgement of the change. Within the present on-line model, the sentence reads: “FBI spokesperson Ben Williamson broadly disputed that such occasions befell.”}
This was dishonest in two respects. First, Mr. Williamson did reply Mr. Dilanian’s questions on these unfounded accusations. He didn’t simply “broadly” deny them. He particularly, and pointedly, refuted them on the file after having researched the matter by chatting with all potential witnesses, explaining that there isn’t any file or corroboration. Second, it was Dilanian who refused to reply questions. Williamson, who was flabbergasted at Dilanian’s full lack of particulars or corroboration, requested him for something that may help the accusations. Their textual content trade was as follows:
WILLIAMSON: This element factor you emailed about seems to be prefer it’s made up. I simply checked. No file of it anyplace and Alexis, who does not even drink, stated it isn’t true. As did Director. Do you’ve got any extra particulars? Common date? Who’s the buddy? Something.
DILANIAN:Â Stand by
WILLIAMSON:Â Do you not have this data already?
DILANIAN: Simply to be clear nobody is saying Alexis was drunk. We do not have the main points you’re in search of however we’re snug with our sourcing. So simply in search of your official remark.
WILLIAMSON: So you don’t have any title, no date vary, no nothing – simply snug together with your sourcing. Are you severe?
Respectfully
Defendants have been, subsequently, particularly conscious previous to publication that the FBI had investigated the allegations and refuted them. Not solely did Defendant Dilanian recklessly disregard this reality, claiming “we’re snug with our sourcing,” however Defendants omitted this data from the Article, falsely implying that the FBI made solely a reflexive and broad denial, and falsely claiming that the FBI had refused to reply questions.
Moreover, Defendant Dilanian lied to the FBI within the textual content trade, falsely claiming that he had no data on the final date of the alleged incident. Had Dilanian supplied the Spring timeframe for the allegation, the FBI might, and would have much more conclusively refuted the story by stating that Ms. Wilkins had no safety element at the moment.
Defendants, in calculated trend, prevented that fact. They knew concerning the current project of Ms. Wilkins’ element by advantage of their very own November 17 article. They knew that in the event that they have been to offer the FBI the Spring timeframe, it might lead to extra than simply the “official remark” they have been trying to get and would derail their desired narrative.
As a result of the alleged occasions didn’t happen, all potential witnesses, together with each member of Ms. Wilkins’ safety element flatly, and rightly, deny the allegations from the Article. And because the FBI has no corroborating data, Defendants’ “nameless” sources couldn’t probably have had first-hand information. If their sources existed in any respect, Defendants knowingly or recklessly disregarded their full lack of awareness and credibility. Defendants knew this and recklessly selected to publish these anonymously sourced lies within the face of on-the-record refutation.
Actually, by saying within the Article that their sources have been “granted anonymity to debate nonpublic issues,” and that they have been “inside accounts,” Defendants falsely counsel to their readers, as supposed, that the sources are official, and even members of Ms. Wilkins’ safety element. This alone is proof of Defendants’ maliciously deliberate obfuscation and information of falsity….
As implicitly acknowledged by Defendant Dilanian, the Article additionally implies that Ms. Wilkins was inebriated. By claiming that on a number of events she was out late after a “evening of partying” with a gaggle of inebriated buddies in Nashville, Tennessee—a metropolis recognized for late-night partying and ingesting—the Article suggests to the common reader that Ms. Wilkins is a heavy drinker. That is solely false, as Ms. Wilkins very not often drinks, if ever. Importantly, Defendants have been on precise discover that this implication was false from Mr. Williamson’s textual content message….
The criticism additionally (1) alleges that the statements have been stated with “precise malice” (i.e., have been knowingly or recklessly false, (2) argues that “Ms. Wilkins will not be a public determine,” in order that the precise malice normal does not apply, and as an alternative “she want solely present that Defendants acted negligently,” and (3) criticizes New York Instances v. Sullivanwhich set forth the precise malice requirement. That final level is in fact not notably related in a Criticism, however presumably Wilkins is planning to boost and protect such a problem within the occasion that the Supreme Court docket may be persuaded to chop again on that precedent, or reduce its extension from public officers (the exact difficulty in Sullivan) to public figures. The criticism additionally features a “false mild” declare, which is carefully associated to a defamation declare: It additionally rests on the statements being allegedly false, however seeks to get better for his or her being “extremely offensive” to the plaintiff and to an affordable individual, fairly than for his or her damaging fame.
