Page:Bauer v. Glatzer - Second Amended Complaint.pdf/11

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	by defendant 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 T. N-Hayden'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 Teresa Nielsen-Hayden for compensatory and punitive damages, together with counsel lees, costs of suit, and other relief as the court may deem proper.

THIRTEENTH COUNT (DEFAMATION)

1.	Plaintiffs repeat and reallege the allegations of the previous COUNTS as if same were set forth at length herein.
2.	Defendant Ann C. Crispin ("Crispin") is an officer and active member of defendant Science Fiction Writers of America, Inc. ("SFWA"), PO Box 877, Chesterton, MD 21620.
3.	At times relevant to this lawsuit, Crispin has, along with defendant Victoria C. Strauss ("Strauss") operated and been responsible for the content of an internet website called Writer Beware ("WB") on behalf of the owner of Writers Beware defendant SFWA.
4.	During the time that Crispin has operated Writer Beware, she has published and continues to publish false and defamatory statements about plaintiffs Barbara Bauer and BBLA on WB, including, but not limited to, posting a list of the "20 Worst Literary Agents", which includes false and defamatory statements about Barbara Bauer, including the statement that Barbara Bauer is among agents that have no "...significant track record of sales to commercial (advance paying) publishers..." This defamatory publication has been posted and quoted extensively on numerous other websites and blogs on the internet.
5.	Crispin has also published and continues to publish false and defamatory statements about plaintiffs on other blogs and websites including, but not limited to, claiming that plaintiff has "...no verified sales to real advance and royalty paying publishers," and characterizing plaintiff as among a group of "questionable agents."