AFTER THE F.B.I. RAIDS

139. As a result of the F.B.I. Raids, JILL ISHKANIAN was
never arrested, never indicted and never charged with any crime.

140. Us WEEKLY never sued JILL ISHKANIAN or SUNSET PHOTO
for any alleged damages caused to them by JILL ISHKANIAN or
SUNSET PHOTO at any time or for any reason.

141. After the F.B.I. Raids, Us WEEKLY staff continued to
email SUNSET PHOTO with Us WEEKLY’s private and confidential
information relating to photographs they were purchasing and how
much they were paying for said photographs.

142. JILL ISHKANIAN was unable to eat or sleep for two
weeks as a result of the DEFENDANTS causing the F.B.I. Raids by
providing the F.B.I. with knowingly false information.

143. JILL ISHKANIAN was unable to go to work or perform any
of her work related duties for at least six months as a result
of the DEFENDANTS causing the F.B.I. Raids by providing the
F.B.I. with knowingly false information.

144. JILL ISHKANIAN’s hair fell out and she was diagnosed
by a medical doctor on or about September 2006 to be suffering
from Post Traumatic Stress Syndrome as a result of the
DEFENDANTS causing the F.B.I. Raids by providing the F.B.I. with
knowingly false information.

145. As a result of the DEFENDANTS causing the F.B.I. Raids
by providing the F.B.I. with knowingly false information, the
Los Angeles Times and numerous other media outlets reported
about the F.B.I. Raids and the accusations against JILL
ISHKANIAN and SUNSET PHOTO.

146. The website TMZ and the newspaper Los Angeles Times
wrote numerous stories about the F.B.I. Raids and JILL ISHKANIAN
and SUNSET PHOTO. These media stories contained intimate
details about the F.B.I. Raids, despite the fact the F.B.I.
Raids were made pursuant to a sealed search warrant.

147. Plaintiffs are informed and believe and on that basis
allege BAKER, MIN, JANN WENNER and WENNER MEDIA and their agents
at their specific direction contacted media outlets, including
the Los Angeles Times and TMZ, and provided them with
information about the F.B.I. Raids as well as knowingly false
information about JILL ISHKANIAN and SUNSET PHOTO allegedly
stealing confidential and proprietary information from Us
WEEKLY. This was done specifically to effectuate Defendants’
Policy and Scheme to Destroy Plaintiffs.

148. Plaintiffs are informed and believe and on that basis
allege these actions were undertaken by DEFENDANTS, and each of
them, with the specific intent to create negative publicity
about JILL ISHKANIAN and SUNSET PHOTO so as to damage their
businesses and reputations and as well as their ability to earn
money in the publishing and news business.

149. Plaintiffs are informed and believe and on that basis
allege that by contacting media sources and providing them with
information about the F.B.I. Raids and by providing them with
knowingly false information about JILL ISHKANIAN and SUNSET
PHOTO, BAKER, MIN, JANN WENNER and WENNER MEDIA had the specific
intent to create negative publicity about the F.B.I. Raids and
JILL ISHKANIAN and SUNSET PHOTO with the specific goal of
hurting JILL ISHKANIAN personally, causing mental distress to
JILL ISHKANIAN personally and ruining JILL ISHKANIAN’s and
SUNSET PHOTO’s businesses and business opportunities.

150. Plaintiffs are informed and believe and on that basis
allege that as a result of the effects of BAKER, MIN, JANN
WENNER and WENNER MEDIA and their agents’ efforts, numerous news
reports were published which negatively reflected on JILL
ISHKANIAN and SUNSET PHOTO.

151. Specifically, these news reports repeated the false
accusations made by DEFENDANTS, and each of them, to the F.B.I.
concerning the false and untrue allegations that JILL ISHKANIAN
and SUNSET PHOTO had illegally taken confidential and or
proprietary information from Us WEEKLY computers after she left
Us WEEKLY.

152. ISHKANIAN is informed and believes and on that basis
alleges that immediately after the F.B.I. Raids, BAKER, with the
knowledge and approval of MIN, called a Los Angeles Times
reporter who also wrote for Us WEEKLY. BAKER asked this
individual to write a negative story about JILL ISHKANIAN’s
business partner in an attempt to effectuate Defendants’ Policy
and Scheme to Destroy Plaintiffs.

153. Plaintiffs are informed and believe and on that basis
allege BAKER, with the knowledge and approval of MIN, made
repeated attempts after the F.B.I. Raids to have the Los Angeles
Times publish additional stories containing knowingly false
accusations about JILL ISHKANIAN and SUNSET PHOTO.

154. On or about October 16, 2006, more than four months
after the F.B.I. Raids, both JILL ISHKANIAN and SUNSET PHOTO
received requests from Us WEEKLY photo editors by phone and in
writing requesting passwords to the SUNSET PHOTO website and to
SUNSET PHOTO File Transfer Protocol.

155. On or about October 16, 2006 JILL ISHKANIAN’s Us
WEEKLY cell phone remained active, paid for by Us WEEKLY.

156. On October 17, 2006 JILL ISHKANIAN, through her
attorney, sent Us WEEKLY editor MIN and Us WEEKLY’s attorney a
cease and desist letter (“Plaintiffs’ Cease and Desist Letter”)
demanding Us WEEKLY: (1) terminate JILL ISHKANIAN’s Us WEEKLY
cell phone; (2) to stop requesting passwords to the SUNSET PHOTO
server and SUNSET PHOTO File Transfer Protocol; and (3) to stop
emailing SUNSET PHOTO about Us Weekly’s photo purchases and
upcoming stories.

157. Plaintiffs’ Cease and Desist Letter was never
responded to in any manner by Us WEEKLY or any agent or
representative of Us WEEKLY.

158. A true and correct copy of Plaintiffs’ Cease and
Desist Letter to Us Weekly is attached hereto as Exhibit “A”.

159. For months after Plaintiffs’ Cease and Desist Letter
and the F.B.I. Raids JILL ISHKANIAN and SUNSET PHOTO received
several confidential emails sent to them by Us WEEKLY. These
emails chronicled exactly what Us WEEKLY was paying for
photographs purchased from Fame Pictures, what the photographs
were of, and described the type of usage each photo would
receive in upcoming issues. Attached hereto as Exhibit “B” are
examples of some of these emails.

160. After Plaintiffs’ Cease and Desist Letter, JILL
ISHKANIAN’s Us WEEKLY cell phone remained active, Us WEEKLY
staff continued to request SUNSET PHOTO server passwords and
continued to email SUNSET PHOTO about Us WEEKLY photo purchases
and upcoming stories.

161. Emails containing confidential and proprietary
information of Us WEEKLY continued to be sent by Us WEEKLY to
JILL ISHKANIAN and SUNSET PHOTO through April 2007.

162. JILL ISHKANIAN and SUNSET PHOTO were effectively
branded as criminals subject to an ongoing F.B.I. criminal
investigation as a result of the DEFENDANTS causing the F.B.I.
Raids by providing the F.B.I. with knowingly false information.

163. Although there were never any indictments or arrests
or charges, the F.B.I. has never released any information or
statement exonerating JILL ISHKANIAN and SUNSET PHOTO.

164. JILL ISHKANIAN’s and SUNSET PHOTO’s ability to gather
news and cultivate news sources has been negatively affected,
thus reducing their profitability and value, as a result of
DEFENDANTS causing the F.B.I. Raids by providing the F.B.I. with
knowingly false information as well as their causing the ensuing
negative publicity.

165. To this day people falsely believe JILL ISHKANIAN and
SUNSET PHOTO remain the subject of a Federal criminal
investigation and, as a result, do not want to deal with or do
business with JILL ISHKANIAN or SUNSET PHOTO.

166. JILL ISHKANIAN’s and SUNSET PHOTO’s gross revenues and
profits were caused to be reduced as a result of the DEFENDANTS
causing the F.B.I. Raids by providing the F.B.I. with knowingly
false information as well as the ensuing negative publicity,.
167. Further damaging JILL ISHKANIAN and SUNSET PHOTO, the
F.B.I. seized and continues to refuse to return JILL ISHKANIAN’s
sources lists, contact lists, and celebrity addresses and
professional notebooks and notes.

168. JILL ISHKANIAN incurred legal fees in an amount in
excess of $50,000 as a result of the F.B.I. Raids.

169. JILL ISHKANIAN incurred medical fees in an amount in
excess of $10,000 as a result of the F.B.I. Raids.