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TWENTY SECOND 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 Valentine 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 Valentine'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 Valentine for compensatory and punitive damages, together with counsel fees, costs of suit, and other relief as the court may deem proper.
TWENTY THIRD COUNT (DEFAMATION)
| 1. | Plaintiffs repeat and reallege the allegations of the previous COUNTS as if same were set forth at length herein. |
| 2. | Defendant Christina Walden ("Walden") resides at 2836 Delaware Street, Oakland, CA 94602. |
| 3. | In or about May 2006 Walden registered and began to operate a website called 20worstagents.com, the very purpose of which was to defame plaintiffs and other literary agents. In a malicious attempt to injure plaintiffs personally and professionally Walden posted an indecent and defamatory photo of plaintiff Bauer superimposed on a list of agents which included BBLA. |
| 4. | The malicious actions of Walden concerning the personal, professional, and business reputation and character of plaintiffs were made maliciously and with intent to destroy plaintiffs' professional reputation and career. |
| 5. | The actions 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. |
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