JILL ISHKANIAN AND SUNSET PHOTO AFTER US WEEKLY

93. Between November 2005 and January 31, 2006, at the
request of Us WEEKLY, JILL ISHKANIAN was paid in excess of
$30,000 by Us WEEKLY for photographs provided through SUNSET
PHOTO to them as well as for reportage relating to those
photographs provided by JILL ISHKANIAN to Us WEEKLY.

94. As of December 31, 2005, two months after resigning,
JILL ISHKANIAN’s Us WEEKLY office voicemail remained active.
JILL ISHKANIAN was able to retrieve messages and to have her
callers informed of her new contact information by way of an
updated, outgoing voicemail message recorded by JILL ISHKANIAN.

95. As of December 31, 2005 JILL ISHKANIAN’s Us WEEKLY
cell phone (323) 270-1335 remained active. Said JILL ISHKANIAN
Us WEEKLY cell phone was not turned off by Us WEEKLY until April
2007.

96. After JILL ISHKANIAN left Us WEEKLY, there were at
least two substantial news stories which served to deteriorate
the professional relationship by and between Plaintiffs and
Defendants.

97. The first occurred on or about January 27, 2006 when
SUNSET PHOTO provided the National Enquirer (a direct competitor
of Us WEEKLY) with exclusive photographs of DENISE RICHARDS
leaving an AIDS testing clinic in Thousand Oaks, California
(“RICHARDS Story”).

98. On or about the end of January 2006, an Us WEEKLY
employee then working as BAKER’s personal assistant called JILL
ISHKANIAN and asked if she had any helpful information to
provide Us WEEKLY.

99. During this phone conversation, and as a professional
courtesy, JILL ISHKANIAN informed the Us WEEKLY staffer the
National Enquirer was publishing a big DENISE RICHARDS story the
next day and that she should look out for it.

100. One week after the National Enquirer published the
RICHARDS Story, Us WEEKLY published a related story entitled:
“Hooker Scandal, Denise’s Final Shock.”

101. Although Us WEEKLY credited the National Enquirer for
breaking the story, they did not use any SUNSET PHOTO
photographs. This fact, in turn, resulted in a professional
dispute between SUNSET PHOTO and Us WEEKLY which, in turn,
resulted in the cessation of business by and between Us WEEKLY
and SUNSET PHOTO.

102. Such interruptions of business between a publication
and a photo agency are commonplace in the publishing industry as
the only means photo agencies have to ensure proper credit for
their work.

103. The second story which contributed to the
deterioration of the professional relationship by and between
Plaintiffs and Defendants occurred on or about April 23, 2006
when SUNSET PHOTO obtained the exclusive, first clear
photographs of RICHIE SAMBORA and DENISE RICHARDS as a couple
(“SAMBORA Story”).

104. Thereafter, SUNSET PHOTO sold the exclusive use of the
SAMBORA Story photographs to another Us WEEKLY competitor.

105. Plaintiffs are informed and believe and on that basis
allege that BAKER, MIN, JANN WENNER and WENNER MEDIA were each
individually and collectively angered by the fact their former
employee, JILL ISHKANIAN, was effectively helping their
competitors obtain exclusive, important stories such as the
RICHARDS Story and the SAMBORA Story. This fact caused
Defendants, and each of them, great concern and consternation.
106. On or about February 1, 2006 Us WEEKLY’s in-house
legal counsel sent JILL ISHKANIAN a letter alleging JILL
ISHKANIAN was providing confidential Us WEEKLY information to
third parties.

107. On or about March 2006 BRITNEY SPEARS’ attorney caused
a subpoena to be served on JILL ISHKANIAN compelling her to give
testimony in a lawsuit between BRITNEY SPEARS and Us WEEKLY
relating to an allegedly false story published by Us WEEKLY
about SPEARS (“BRITNEY SPEARS Case”).

108. On or about April 20, 2006 JILL ISHKANIAN was deposed
by BRITNEY SPEARS’ attorney in the BRITNEY SPEARS Case. During
her deposition JILL ISHKANIAN gave truthful testimony
unfavorable to Us WEEKLY regarding the subject matter of the
BRITNEY SPEARS Case.

109. Plaintiff is informed and believes and on that basis
alleges that the testimony provided by JILL ISHKANIAN in the
BRITNEY SPEARS Case caused Defendants, and each of them, great
concern, anger and consternation.

110. Plaintiffs are informed and believe and on that basis
allege that BAKER, MIN, JANN WENNER and WENNER MEDIA, approved,
instituted and implemented a policy and scheme to destroy JILL
ISHKANIAN’s and SUNSET PHOTO’s professional reputation, ability
to gather and report celebrity news and information, and to
maintain a profitable and reputable business (“Policy and Scheme
to Destroy Plaintiffs”).

111. There were multiple motivational factors contributing
to Defendants’ Policy and Scheme to Destroy Plaintiffs. These
included but were not limited to:

A. JILL ISHKANIAN’s disagreement with BAKER’s hiring
unqualified reporters;

B. JILL ISHKANIAN’s disagreement with BAKER’s
reporting techniques and ethics;

C. JILL ISHKANIAN’s disagreement with BAKER about
his behavior toward female employees while she worked
at Us WEEKLY;

D. JILL ISHKANIAN’s disagreement with BAKER and MIN
taking credit for important stories she reported and
broke and their not giving JILL ISHKANIAN credit;

E. JILL ISHKANIAN’s refusal to lie on behalf of
BAKER relating to his behavior towards females working
at Us WEEKLY;

F. JILL ISHKANIAN’s disagreement with Us WEEKLY’s
policy of taking personal property sent to Us WEEKLY;

G. JILL ISHKANIAN’s objection to the use of
editorial positions for private gain (e.g. t-shirt
promotion and book party promotions) and to obtain
personal wealth and property;

H. JILL ISHKANIAN’s truthful deposition testimony in
the BRITNEY SPEARS Case;

I. that JILL ISHKANIAN and SUNSET PHOTO were
successful in their endeavor to open and run a photo
agency selling high end, important photographs to the
direct competitors of Us WEEKLY, as exemplified by the
RICHARDS Story and the SAMBORA Story.

112. Plaintiffs are informed and believe and on that basis
allege that BAKER, MIN, JANN WENNER and WENNER MEDIA either
directly or through their personal direction to their agents and
employees, and as part of their Policy and Scheme to Destroy
Plaintiffs, contacted each and every JILL ISHKANIAN news source
to convince them to become sources for Us WEEKLY and to not give
information to PLAINTIFFS.

113. Plaintiffs are informed and believe and on that basis
allege that as part of their Policy and Scheme to Destroy
Plaintiffs, BAKER, MIN, JANN WENNER and WENNER MEDIA either
directly or through direction to their agents and employees,
told numerous people JILL ISHKANIAN’s new business, SUNSET
PHOTO, would fail.

114. After the implementation of the Policy and Scheme to
Destroy Plaintiffs, Us WEEKLY continued to send JILL ISHKANIAN’s
business partner confidential emails about Us WEEKLY business.

115. Us WEEKLY continued to send SUNSET PHOTO confidential
emails relating to Us WEEKLY stories and story ideas through
April 2007.