Page:Bauer v. Glatzer - Second Amended Complaint.pdf/28

	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 Narayan'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 Narayan for compensatory and punitive damages, together with counsel fees, costs of suit, and other relief as the court may deem proper.

THIRTY 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 Kristen Fischer aka Kristen Pascuili ("Fischer") who resides at 3905 Herbertsville Rd. Point Pleasant, New jersey 08742, owns and operates a website called Kristen Fischer.com ("KF.com"), and blog called Written Out Loud ("WOL").
3.	Fischer has published and continues to publish numerous false and defamatory statements about plaintiffs Barbara Bauer and BBLA on KF.com and WOL including, but not limited to saying that the plaintiffs have "...no verifiable record of sales to commercial publishing houses...", and have "...no documented and verified sales at all...."
4.	The false and defamatory statements made by Fischer 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 Fischer 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 Fischer'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.

28