Did the NYT provide her with a burner phone?
The ruling only says that Mary Trump and one of the reporters (Craig) used burner phones. There’s nothing in the ruling that says who supplied the phones.
However, I’m willing to bet that it is neither unusual, nor illegal, for a reporter to supply a potential source w/ a burner phone.
The courts hold that the press is protected from tort liability for “legal and ordinary newsgathering activities.”
If the press had stolen the documents from Ms. Trump’s home or from her lawyers office that would be a different matter.