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| 3. | Lugwig has published and continues to publish numerous false and defamatory statements about plaintiffs Barbara Bauer and BBLA on Webusers and other websites and blogs including, but not limited to saying, "Barabara Bauer a scammer." |
| 4. | The false and defamatory statements made by Lugwig 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 Lugwig 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 Lugwig'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 Lugwig'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 Lugwig'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 Spencer for compensatory and punitive damages, together with counsel fees, costs of suit, and other relief as the court may deem proper.
THIRTY EIGHTH 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 Lugwig 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. |
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