Open main menu

Page:Bauer v. Glatzer - Second Amended Complaint.pdf/12

This page has been validated.
6. The false and defamatory statements made by Crispin concerning the personal, professional, and business reputation and character of plaintiffs were made maliciously and with intent to destroy plaintiffs' professional reputation and career.
7. The statements made by Crispin 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.
8. As a direct and proximate result of defendant Crispin'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.
9. As a direct and proximate result of defendant Crispin's conduct, plaintiff Barbara Bauer has suffered and will continue to suffer extreme mental anguish and distress.
10. As a direct and proximate result of defendant Crispin'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 Crispin for compensatory and punitive damages, together with counsel fees, costs of suit, and other relief as the court may deem proper.

FOURTEENTH 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 Crispin 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.
3. As a direct and proximate result of defendant Crispin'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.

12