This page has been validated.
| 4. | During the time that Glatzer owned and operated AW, she has published and continues to publish numerous false and defamatory statements about plaintiffs Barbara Bauer and BBLA on AW, 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...," claiming that plaintiff is not just a bad agent but a "scammer", that she is among agents who "...vacuum out your savings account..." and "...lie to you...," and that she has threatened 2/3 of the internet at least once." |
| 5. | The false and defamatory statements made by Glatzer concerning the personal, professional, and business reputation and character of plaintiffs were made maliciously and with intent to destroy plaintiffs' professional reputation and career. |
| 6. | The statements made by Glatzer 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. |
| 7. | As a direct and proximate result of defendant Glatzer's conduct, plaintiff Barbara Bauer has been impaired in her ability to earn a living as a literary agent, and has sustained and will continue to sustain loss of income in amounts that will be established at trial. |
| 8. | As a direct and proximate result of defendant Glatzer's conduct, plaintiff Barbara Bauer has suffered and will continue to suffer extreme mental anguish and distress. |
| 9. | As a direct and proximate result of defendant Glatzer'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 Glatzer for compensatory and punitive damages, together with counsel fees, costs of suit, and other relief as the court may deem proper.
SECOND COUNT (TORTIOUS INTERFERENCE WITH PROSPECTIVE ECONOMIC ADVANTAGE)
| 1. | Plaintiffs repeat and reallege the allegations of the previous COUNT as if same were set forth at length herein. |
