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WHEREFORE, plaintiffs request judgment against defendant Stone for compensatory and punitive damages, together with counsel fees, costs of suit, and other relief as the court may deem proper.
FIFTH COUNT (DEFAMATION)
| 1. | Plaintiffs repeat and reallege the allegations of the previous COUNTS as if same were set forth at length herein. |
| 2. | Defendant James D. MacDonald ("MacDonald") resides at 127 Main Street, Colebrooke, NH 03576.. |
| 3. | Both on his own blog and on other sites on the internet MacDonald has published and continues to publish false and defamatory statements about plaintiffs Barbara Bauer and BBLA including, but not limited to, claiming that Barbara Bauer is among agents that have no "...significant track record of sales to commercial (advance paying) publishers...," that she is among agents who "...vacuum out your savings account..." and "...lie to you..., " and that she is a "...dodgy player." |
| 4. | The false and defamatory statements made by MacDonald concerning the personal, professional, and business reputation and character of plaintiffs were made maliciously and with intent to destroy plaintiffs' professional reputation and career. |
| 5. | The statements made by MacDonald 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. |
| 6. | As a direct and proximate result of defendant MacDonald'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. |
| 7. | As a direct and proximate result of defendant MacDonald's conduct, plaintiff Barbara Bauer has suffered and will continue to suffer extreme mental anguish and distress. |
| 8. | As a direct and proximate result of defendant MacDonald'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. |
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