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WHEREFORE, plaintiffs request judgment against defendant Amodio Foundation for compensatory and punitive damages, together with counsel fees, costs of suit, and other relief as the court may deem proper.
FORTIETH COUNT (TORTIOUS INTERFERENCE WITH PROSPECTIVE ECONOMIC ADVANTAGE)
| 1. | Plaintiff's repeat and reallege the allegations of the previous COUNTS as if same were set forth at length herein. |
| 2. | The publication by defendant Amodio the false and malicious statements about plaintiffs set forth in the previous COUNT, as well as other actions and statements by defendant Amodio, 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 Amodio'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 Amodio for compensatory and punitive damages, together with counsel fees, costs of suit, and other relief as the court may deem proper.
FORTY FIRST COUNT (CONSPIRACY TO DEFAME)
| 1. | Plaintiffs repeat and reallege the allegations of the previous COUNTS as if same were set forth at length herein. |
| 2. | Defendants Jenna Glatzer, MacAllister Stone, James D. MacDonald, Kent Brewster, Ann C. Crispin, Patrick Nielsen-Hayden, Teresa Nielsen Hayden, Brian Hill, Dee Power aka Harrilane D. Power aka D. Carr Harrilane, David L Kuzminski, Thomas S. Tully, Science Fiction and Fantasy Writers of America, Inc., Victoria C.Strauss, Shweta Narayan, Lesia Valentine, Christina Walden aka Christina Bristol, Wikimedia Foundation, Stephan Spencer, Kristen Fischer aka Kristen Pascuili, Gregory Ludwig, and Aimee Amodio conspired and acted in concert with each other, as well as with other unnamed individuals and entities, to defame plaintiffs by publishing the false and malicious statements about plaintiffs set forth in the FIRST, THIRD, FIFTH, SEVENTH, NINTH, ELEVENTH, THIRTEENTH, FIFTEENTH, |
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