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| 7. | As a direct and proximate result of defendant Fischer'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 Fischer'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 Fischer for compensatory and punitive damages, together with counsel fees, costs of suit, and other relief as the court may deem proper.
THIRTY 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 Fischer of the false and malicious statements about plaintiffs set forth in the previous COUNT, 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 Fischer'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 Fischer for compensatory and punitive damages, together with counsel fees, costs of suit, and other relief as the court may deem proper.
THIRTY SEVENTH COUNT (DEFAMATION)
| 1. | Plaintiffs repeat and reallege the allegations of the previous COUNTS as if same were set forth at length herein. |
| 2. | Gregory Ludwig ("Ludwig") who resides at 4 Ye Olde Log Tavern Drive, Highland Lakes, NJ 07422-0289 owns and operates a website called webusers.warwick.net ("Webusers") and he is a regular contributor to a blog run by Ann Crispin and Victoria Strauss.. |
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