This page has been validated.
WHEREFORE, plaintiffs request judgment against defendant Hill and Power for compensatory and punitive damages, together with counsel lees, costs of suit, and other relief as the court may deem proper.
TWENTY FIRST COUNT (DEFAMATION)
| 1. | Plaintiffs repeat and reallege the allegations of the previous COUNTS as if same were set forth at length herein. |
| 2. | Defendant Lesia Valentine, ("Valentine") address unknown, produced the You Tube videos about Barbara Bauer entitled "Crouching Snark, Hidden Dragon" and "Miss Snark's Happy Hooker Crapstravaganza", featuring defendant Snark, which belittle and defame plaintiffs with false and defamatory images and statements about plaintiff Barbara Bauer. |
| 3. | The false and defamatory statements made by Valentine concerning the personal, professional, and business reputation and character of plaintiffs were made maliciously and with intent to destroy plaintiffs' professional reputation and career. |
| 4. | The statements made by Valentine 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. |
| 5. | As a direct and proximate result of defendant Valentine'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. |
| 6. | As a direct and proximate result of defendant Valentines's conduct, plaintiff Barbara Bauer has suffered and will continue to suffer extreme mental anguish and distress. |
| 7. | As a direct and proximate result of defendant Valentine'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 Valentine for compensatory and punitive damages, together with counsel fees, costs of suit, and other relief as the court may deem proper.
18
