The following is an additional cause of action that may be brought against a spouse. This material can be incorporated, if appropriate, as an integral part of the divorce pleading to be inserted as a paragraph preceding the prayer. (If the material is incorporated in the respondent’s pleading, it should be reworded to reflect that the respondent, rather than the petitioner, is the complainant.)
Tortious Interference with Business Relations
1.Tortious Interference with Business Relations
On [date] and continuing thereafter, Respondent, without privilege or justification, engaged in conduct that intentionally and willfully interfered with the business relationship of Petitioner and [name]. At the time that conduct occurred, Petitioner had a reasonable expectation of a continuing business relationship with [name], and Respondent knew of that reasonable expectation. Respondent’s interference with the business relationship induced or caused the termination of this expectancy.
2.Damages
This action proximately resulted in damages to Petitioner for which Petitioner now seeks relief. Those damages include [state specific damages alleged].
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Include 3. if applicable. |
Respondent acted with malice in engaging in this conduct, thus entitling Petitioner to exemplary damages within the jurisdictional limits of this Court.
4.Prayer
Petitioner prays for judgment against Respondent in a sum within the jurisdictional limits of this Court for [his/her] actual damages as alleged, [include if applicable: for exemplary damages,] for prejudgment and postjudgment interest as allowed by law, for costs of court, and for general relief.