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| 8. | As a direct and proximate result of defendant Tully'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 Tully for compensatory and punitive damages, together with counsel fees, costs of suit, and other relief as the court may deem proper.
TWENTY EIGHTH 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 Tully 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 Tully'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 Tully for compensatory and punitive damages, together with counsel fees, costs of suit, and other relief as the court may deem proper.
TWENTY NINTH COUNT (DEFAMATION)
| 1. | Plaintiffs repeat and reallege the allegations of the previous COUNTS as if same were set forth at length herein. |
| 2. | Defendant Stephan Spencer ("Spencer"), whose place of business is at 2820 Walton Commons West, Suite 123, Madison, WI 53718, owns and operates a website at writer.net. |
| 3. | Defendant Spencer has published and continues to publish numerous false and defamatory statements about plaintiffs Barbara Bauer and BBLA on writers.net, including, but not limited to saying that plaintiff "...is a crook...," "... a thief...," |
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