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| 4. | The false and defamatory statements and images made and created by Hill and Power 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 Hill and Power clearly denigrated plaintiffs' reputation, and accused her of engaging in conduct and having trails 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 Hill and Power'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 Hill and Power'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 Hill and Power'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. |
WHEREFORE, plaintiffs request judgment against defendant Hill and Power for compensatory and punitive damages, together with counsel fees, costs of suit, and other relief as the court may deem proper.
TWENTIETH 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 Hill and Power 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 Hill and Power'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. |
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