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SEVENTEENTH, NINETEENTH, TWENTY FIRST, TWENTY THIRD, TWENTY FIFTH, TWENTY SEVENTH, TWENTY NINTH, THIRTY FIRST, THIRTY THIRD, THIRTY FIFTH, THIRTY SIXTH, THIRTY SEVENTH and THIRTY NINTH COUNTS herein, as well as other defamatory statements. | |
| 3. | The false and defamatory statements made by these defendants, acting in concert, concerning the personal, professional, and business reputation and character of' plaintiffs were made maliciously and with intent to destroy plaintiffs' professional reputation and career. |
| 4. | The statements made by these defendants, acting in concert, 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. |
| 5. | As a direct and proximate result of the joint conduct of these defendants 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. |
| 6. | As a direct and proximate result of the joint conduct of these defendants, plaintiff Barbara Bauer has suffered and will continue to suffer extreme mental anguish and distress. |
| 7. | As a direct and proximate result of the joint conduct of these defendants, 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 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 for compensatory and punitive damages, together with counsel lees, costs of suit, and other relief as the court may deem proper.
