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WHEREFORE, plaintiffs request judgment against defendant Crispin for compensatory and punitive damages, together with counsel fees, costs of suit, and other relief as the court may deem proper.
FIFTEENTH COUNT (DEFAMATION)
| 1. | Plaintiffs repeat and reallege the allegations of the previous COUNTS as if same were set forth at length herein. |
| 2. | Defendant Victoria C. Strauss is an officer and active member of defendant Science Fiction and Fantasy Writers of America, Inc. ("SFWA"), PO Box 877, Chesterton, MD 21620, and resides at 27 Cosby Ave., Amherst, MA 01002. |
| 3. | At times relevant to this lawsuit, Strauss has along with defendant Crispin operated Writer Beware on behalf of SFWA and been responsible for its content. |
| 4. | During the time that Strauss has operated Writer Beware, she has published and continues to publish false and defamatory statements about plaintiffs Barbara Bauer and BBLA on WB, including, but not limited to, posting a list of the "20 Worst Literary Agents", which includes false and defamatory statements about Barbara Bauer, including the statement that Barbara Bauer is among agents that have no "...significant track record of sales to commercial (advance paying) publishers..." This defamatory publication has been posted and quoted extensively on numerous other websites and blogs on the internet. Strauss has also referred to plaintiff on WB as a "...scam agent..." and alleged that she engages in "...dirty business practices..." |
| 5. | Strauss has also published and continues to publish false and defamatory statements about plaintiffs on other blogs and websites including, but not limited to claiming that plaintiff has "...no documented and verified sales at all." |
| 6. | The false and defamatory statements made by Strauss concerning the personal, professional, and business reputation and character of plaintiffs were made maliciously and with intent to destroy plaintiffs' professional reputation and career. |
| 7. | The statements made by Strauss clearly denigrated plaintiffs' reputation, and accused her of engaging in conduct and having traits incompatible with her business as a literary agent, and are thus defamatory per se under New Jersey law. |
| 8. | As a direct and proximate result of defendant Strauss's conduct, plaintiff Barbara Bauer has been impaired in her ability to earn a living as a literary agent, and has |
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