This page has been validated.
WHEREFORE, plaintiffs request judgment against defendant MacDonald for compensatory and punitive damages, together with counsel fees, costs of suit, and other relief as the court may deem proper.
SIXTH 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 MacDonald 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 MacDonald'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 MacDonald for compensatory and punitive damages, together with counsel fees, costs of suit, and other relief as the court may deem proper
SEVENTH COUNT (DEFAMATION)
| 1. | Plaintiffs repeat and reallege the allegations of the previous COUNTS as if same were set forth at length herein. |
| 2. | Defendant Kent Brewster ("Brewster") resides at PMB 400, #109, 111 West El Camino Real, Sunnyvale, CA 94087-1057. |
| 3. | At times relevant to this lawsuit, Brewster has owned and operated and been responsible for the content of an internet website called Speculations.com ("Speculations"). |
| 4. | Brewster has published and continues to publish numerous false and defamatory statements about plaintiffs Barbara Bauer and BBLA on Speculations, 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...," calling her the "Dumbest of the 20 Worst" agents, |
