THE F.B.I. RAIDS

116. On May 23, 2006 the Federal Bureau of Investigation
(“F.B.I.”) raided JILL ISHKANIAN’s home and the SUNSET PHOTO
offices. The F.B.I. entered JILL ISHKANIAN’s home pursuant to
a search warrant. When the F.B.I. entered JILL ISHKANIAN’s home
JILL ISHKANIAN was asleep in her bed. The F.B.I. entered JILL
ISHKANIAN’s home at 6 a.m.

117. During the raid, twelve F.B.I. agents in flak jackets
entered JILL ISHKANIAN’s home with their guns drawn and held
their guns to JILL ISHKANIAN’s head and to the head of JILL
ISHKANIAN’s boyfriend.

118. JILL ISHKANIAN and her boyfriend were placed into
handcuffs, removed from their home and placed into a police
vehicle. They were never arrested nor taken to any other
location during the more than two hour raid.

119. The handcuffs for JILL ISHKANIAN were too small,
resulting in physical damage to her right wrist, which swelled
to three times its normal size.

120. Neither JILL ISHKANIAN nor her boyfriend had any
criminal history or record of any kind or nature.

121. Fifteen F.B.I. agents raided SUNSET PHOTO’s offices
in West Hollywood. These two F.B.I. raids on JILL ISHKANIAN’s
home and SUNSET PHOTO’s office shall be collectively referred to
herein as the “F.B.I. Raids”.

122. During the F.B.I. Raids the F.B.I. confiscated and
removed JILL ISHKANIAN’s personal bank records, her computer
hard drives containing her emails, her business partners’
personal bank records, her business bank records, as well as
files on DENISE RICHARDS and CHARLIE SHEEN.

123. During the F.B.I. Raids the F.B.I. destroyed a brand
new Macintosh computer as well as an $8,000 “Raid” memory device
used to store photographs.

124. The F.B.I. returned JILL ISHKANIAN’s business
partners’ records and SUNSET PHOTO business records on or about
December 2006. To this date the F.B.I. has not returned any of
JILL ISHKANIAN’s personal property obtained during the F.B.I.
Raids.

125. Plaintiffs are informed and believe and on that basis
allege the F.B.I. Raids were a result of the concerted efforts
of Defendants’ Policy and Scheme to Destroy Plaintiffs.

126. Plaintiffs are informed and believe and on that basis
allege BAKER, MIN, JANN WENNER and WENNER MEDIA each together,
separately and by direction to third party agents and employees
knowingly provided false information to the F.B.I. so as to
instigate and cause the F.B.I. Raids against JILL ISHKANIAN.

127. Plaintiffs are informed and believe and on that basis
allege BAKER, MIN, JANN WENNER and WENNER MEDIA and their
agents, including retired F.B.I. agents working for and at the
direction of BAKER, MIN, JANN WENNER and WENNER MEDIA, told the
F.B.I. that JILL ISHKANIAN and SUNSET PHOTO was using Us WEEKLY
computers and Us WEEKLY emails to garner unauthorized,
confidential and privileged information for use by Plaintiffs.

128. Plaintiffs are informed and believe and on that basis
allege Us WEEKLY’s accusations made to the F.B.I. against
Plaintiffs were known to have been false when made by BAKER,
MIN, JANN WENNER and WENNER MEDIA and their agents, including
retired F.B.I. agents working for BAKER, MIN, JANN WENNER and
WENNER MEDIA.

129. Plaintiffs are informed and believe and on that basis
allege the truth known to BAKER, MIN, WENNER MEDIA AND JANN
WENNER and their agents at the time they spoke and or directed
others to speak with the F.B.I. was that Us WEEKLY was paying
JILL ISHKANIAN and SUNSET PHOTO to provide Us WEEKLY
information, reportage, and photographs through the end of
January 2006.

130. Plaintiffs are informed and believe and on that basis
allege that the truth known to BAKER, MIN, JANN WENNER AND
WENNER MEDIA at the time each of them spoke to or caused others
to speak to the F.B.I. about JILL ISHKANIAN was that, as
detailed herein above, Us WEEKLY had ineffective, lax, slipshod,
shoddy, slapdash, slack, and negligent security in place at
their Los Angeles Office which regularly and routinely resulted
in the unauthorized access to Us WEEKLY computers and Us WEEKLY
confidential information by unauthorized third parties other
than JILL ISHKANIAN and or SUNSET PHOTO.

131. Plaintiffs are informed and believe and on that basis
allege the truth known to BAKER, MIN, JANN WENNER and WENNER
MEDIA and their agents at the time they spoke with the F.B.I.
and or directed third parties to speak to the F.B.I. was that Us
WEEKLY was voluntarily and on their own accord providing JILL
ISHKANIAN and SUNSET PHOTO with Us WEEKLY’s and their agents’
confidential information, including computer passwords and
access codes as well as information about photographs Us WEEKLY
were purchasing and the prices they were paying for said
photographs.

132. Plaintiffs are informed and believe and on that basis
allege the truth of the matter was that the F.B.I. Raids were a
result of the provision of knowingly false information provided
to the F.B.I. by BAKER, WENNER MEDIA, JANN WENNER AND MIN and
their agents for the sole purpose of creating a media story by
which they could effectuate their Policy and Scheme to Destroy
Plaintiffs.

133. Plaintiffs are informed and believe and on that basis
allege that other than making knowingly false statements to the
F.B.I. about JILL ISHKANIAN, BAKER, MIN, JANN WENNER and WENNER
MEDIA nor any of their agents took any action of any kind or
nature to investigate or remediate any alleged security breach
perpetrated against them by JILL ISHKANIAN and SUNSET PHOTO.

134. Plaintiffs are informed and believe and on that basis
allege BAKER, MIN, JANN WENNER and WENNER MEDIA knew at the time
they were making and or causing their agents to make knowingly
false accusations to the F.B.I. about JILL ISHKANIAN and SUNSET
PHOTO that Us WEEKLY routinely failed to abide by any of their
own security measures and that security at Us WEEKLY was
effectively nonexistent.

135. Plaintiffs are informed and believe and on that basis
allege BAKER, MIN, JANN WENNER and WENNER MEDIA knew at the time
they were making and or causing their agents to make knowingly
false accusations to the F.B.I. about JILL ISHKANIAN and SUNSET
PHOTO that JILL ISHKANIAN and SUNSET PHOTO had been providing Us
WEEKLY with professional services through January 2006 in the
form of news information, reportage, stories and photographs for
which Us WEEKLY paid JILL ISHKANIAN and SUNSET PHOTO.

136. Plaintiffs are informed and believe and on that basis
allege BAKER, MIN, JANN WENNER and WENNER MEDIA knew at the time
they were making and or causing their agents to make knowingly
false accusations to the F.B.I. about JILL ISHKANIAN and SUNSET
PHOTO that Us WEEKLY was continuing to send JILL ISHKANIAN, her
business partners and SUNSET PHOTO emails containing information
about stories Us WEEKLY was working on as well as prices paid
for photographs purchased by Us WEEKLY.

137. Plaintiffs are informed and believe and on that basis
allege when their knowingly false statements were made to the
F.B.I. regarding JILL ISHKANIAN and SUNSET PHOTO, BAKER, MIN,
JANN WENNER and WENNER MEDIA and their agents knew that the Us
WEEKLY computer system, computer usernames and computer
passwords were regularly and routinely compromised and
distributed to non-Us WEEKLY third parties, as detailed herein
above.

138. During the F.B.I. Raids, the F.B.I. took all of JILL
ISHKANIAN’s reporting notebooks containing valuable source and
other information. These notebooks have never been returned to