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| 3. | Kuzminski has published and continues to publish numerous false and defamatory statements about plaintiffs Barbara Bauer and BBLA on P&E and other websites and blogs, including, but not limited to referring to plaintiff on numerous occasions as a “...scammer...” and a “...scam...” and stating that plaintiff”...doesn't have any legitimate sales...” |
| 4. | The false and defamatory statements made by Kuzminski 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 Kuzminski 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 Kuzminski'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 Kuzminski'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 Kuzminski'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 Kuzminski for compensatory and punitive damages, together with counsel fees, costs of suit, and other relief as the court may deem proper.
TWENTY 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 Kuzminski of the false and malicious statements about plaintiffs set forth in the previous COUNT, as well as other actions and |
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