According to the amended lawsuit, obtained by TMZ, the basis for the new claim is Cohen's statement, "Just because something isn't true doesn't mean that it can't cause you harm or damage."
Daniels' lawyer, Michael Avenatti, says in the lawsuit, "It was reasonably understood Mr. Cohen meant to convey that Ms. Clifford is a liar, someone who should not be trusted, and that her claims about her relationship with Mr. Trump is 'something [that] isn't true.'"
Avenatti says Cohen's statement subjected her to physical threats of violence to her person and life, as well as hatred, contempt, ridicule, and shame.
She's seeking both actual and punitive damages.
The new complaint also seeks to keep the lawsuit against Donald Trump in the courts. As you know, Avenatti is trying to get the confidentiality agreement Daniels signed invalidated and Trump wants the matter handled privately in arbitration. The amended lawsuit specifically asks the judge to rule no arbitration agreement was agreed upon.