Page:Bauer v. Glatzer - Second Amended Complaint.pdf/9

9.	As a direct and proximate result of defendant P. N-Hayden'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 Patrick Nielsen-Hayden for compensatory and punitive damages, together with counsel fees, costs of suit, and other relief as the court may deem proper.

TENTH 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. statements by defendant interfered with the prospective economic advantage of plaintiffs by inducing prospective clients not to engage plaintiff as their literary agent.
2.	As a direct and proximate result of defendant P. 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.
3.	As a direct and proximate result of defendant P. 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 Patrick Nielsen-Hayden for compensatory and punitive damages, together with counsel fees, costs of suit, and other relief as the court may deem proper.

ELEVENTH COUNT (DEFAMATION)

1.	Plaintiffs repeat and reallege the allegations of the previous COUNTS as if same were set forth at length herein.
2.	Teresa Nielsen-Hayden (“T. N-Hayden”) is employed at TOR Books, 175 Fifth Avenue, New York, NY 10010.
3.	At all times relevant to this lawsuit, T. N-Hayden has owned and operated and been responsible for the content of an internet website called “Making Light”.