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| 3. | As a direct and proximate result of defendant Spencer'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 Spencer for compensatory and punitive damages, together with counsel fees, costs of suit, and other relief as the court may deem proper.
THIRTY FIRST COUNT (DEFAMATION)
| 1. | Plaintiffs repeal and reallege the allegations of the previous COUNTS as if same were set forth at length herein. |
| 2. | Defendant Wikimedia Foundation ("WF"), with offices at 200 Second Avenue South, # 358, St. Petersburg, FL 33701-4313, owns and operates Wikipedia, an online encyclopedia. |
| 3. | Defendant WF has published and continues to publish numerous false and defamatory statements about plaintiffs Barbara Bauer and BBLA including, but not limited to, referring to plaintiff as "The Dumbest of the Twenty Worst" literary agents, and stating that she "no documented sales at all." |
| 4. | The false and defamatory statements made by WF 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 WF 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 WF'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 WF's conduct, plaintiff Barbara Bauer has suffered and will continue to suffer extreme mental anguish and distress. |
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