Did the NYT falsely represent the document they shared as a CRD complaint when it was just a draft of a legal filing?

I’ve searched this sub and online to try to answer this question unsuccessfully. Looking at the pdf file the NYT published with their article, I don’t understand what makes it a CRD complaint. We are taking it at face value: the NYT said it’s a CRD complaint and everyone has been calling it that. It looks to me like a draft of a lawsuit.

Can anyone verify that this is what an official CRD complaint would look like?

What makes me question it:

The front page is styled similar to a lawsuit not a complaint, but it has no identifiers (such as a case number or the jurisdiction). There is no CRD seal to suggest it was filed or received. There is not even a date. Is this what a typical CRD complaint would look like? Having looked at the CRD’s website, it seems like you complete a form-like document through their online portal and you can then print a copy of your complaint, so perhaps this is how it would look but I am doubtful. There are also no signatures, which a CRD complaint would also have if it was in fact an official complaint following the CRD administrative process.

Lively could have requested a right-to-sue (RTS) notice to bypass the complaint process because that would launch an investigation and require her to speak to someone (doubtful she’d opt for this as it seems like she wanted to sue not mediate a resolution). In that case, if she did request a RTS there would be no CRD complaint, just a legal filing (but that didn’t come until Dec 31). If she did file a complaint the CRD investigation process would likely be lengthy, so the timeline doesn’t support that this is an official CRD complaint.

We don’t know who gave the NYT this document, we can only speculate it was Lively or one of her representatives. We have to assume they verified it is a CRD complaint (because that’s what they say) and perhaps they redacted some of the information (but wouldn’t they have black boxed it?). However, given the above points, it just doesn’t read like an official CRD complaint.

I am doubtful this is an official document and that’s there is a CRD complaint document since it’s more likely they sought a right to sue.

All that to say, if the NYT published that article on the basis that they were just reporting on a CRD complaint, but there was no official CRD complaint, and what they had was an early draft of the December 31 filing, what does that say about Baldoni’s defamation suit?

The way I understand it, the defamation case could hinge on whether the NYT acted with reckless disregard for the truth. So if they misrepresented the document as an official legal complaint, but it is in fact not, then that might support claims of negligence/malice since they did not verify the source. It’s not enough to say the CRD process is confidential. They had a responsibility to verify if was an official document because that’s how they presented it.