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| 2. | The publication by defendant Glatzer 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 Glatzer'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 Glatzer for compensatory and punitive damages, together with counsel fees, costs of suit, and other relief as the court may deem proper.
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 MacAllister Stone resides at 8911 Vernon Rd., M-#165, Everett (Lake Stevens), WA 98205. |
| 3. | At times relevant to this lawsuit, Stone has owned and operated and been responsible for the content of an internet website called AbsoluteWrite.com ("AW") |
| 4. | During the time that Stone 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 … ," including 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. | Stone has also published and continues to publish false and defamatory statements about plaintiffs on her own blog including, but not limited to, calling plaintiff an" … inept-but-abusive supposed literary agent." |
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