Page:Bauer v. Glatzer - Second Amended Complaint.pdf/16

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

EIGHTEENTH 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 SFWA on WB 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 SFWA'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 SFWA for compensatory and punitive damages, together with counsel fees, costs of suit, and other relief as the court may deem proper.

NINETEENTH COUNT (DEFAMATION)

1.	Plaintiffs repeat and reallege the allegations of the previous COUNTS as if same were set forth at length herein.
2.	Defendant Brian Hill ("Hill"), and Dee Power aka D. Carr Harrilane ("Power") reside at 11832 N. Winchester Drive, Fountain Hills, AZ 85268.
3.	Hill and Power own and operate The Snark Blog on which they make Internet postings under the fictitious name "Miss Snark, The Literary Agent." Hill and Power, as "Miss Snark" have published false and defamatory statements about plaintiffs Barbara Bauer and BBLA on its blog, including, but not limited to, calling plaintiff a "scam artist", and referring to her associates as "her posse of dumbshits." Snark has produced and caused to be published on You Tube videos about Barbara Bauer entitled "Crouching Snark, Hidden Dragon" and "Miss Snark's Happy Hooker Crapstravaganza", the purpose of which were to belittle and defame plaintiffs with false and defamatory images and statements about plaintiff.

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