Page:Bauer v. Glatzer - Second Amended Complaint.pdf/14

	sustained and will continue to sustain loss of income in amounts that will be established at trial.
9.	As a direct and proximate result of defendant Strauss's conduct, plaintiff Barbara Bauer has suffered and will continue to suffer extreme mental anguish and distress.
10.	As a direct and proximate result of defendant Strauss's conduct, the reputation of BBLA has been damaged and it has sustained and will continue to sustain loss of income in amounts that will be established at trial.

WHEREFORE, plaintiffs request judgment against defendant Strauss for compensatory and punitive damages, together with counsel fees, costs of suit, and other relief as the court may deem proper.

SIXTEENTH COUNT (TORTIOUS INTERFERENCE WITH PROSPECTIVE ECONOMIC ADVANTAGE)

1.	Plaintiffs repeat and reallege the allegations of the previous COUNTS as if same were set forth at length herein.
2.	The publication by defendant Strauss of the false and malicious statements about plaintiffs set forth in the previous COUNT, as well as other actions and statements by defendant interfered with the prospective economic advantage of plaintiffs by inducing prospective clients not to engage plaintiff as their literary agent.
3.	As a direct and proximate result of defendant Strauss's malicious inducement to potential clients of plaintiffs not to engage plaintiff as their literary agent, plaintiffs suffered damages in amounts that will be established at trial.

WHEREFORE, plaintiffs request judgment against defendant Strauss for compensatory and punitive damages, together with counsel fees, costs of suit, and other relief as the court may deem proper.

SEVENTEENTH COUNT (DEFAMATION)

1.	Plaintiffs repeat and reallege the allegations of the previous COUNTS as if same were set forth at length herein.
2.	Defendant SFWA is a corporation doing business at 332 LaGuardia Plaintiff., #632, NY, NY 10012-1428 and PO Box 877, Chestertown, MD 21620.
3.	At times relevant to this lawsuit, SFWA has owned WB, and has operated it through its agents defendants Crispin and Strauus.