31. Plaintiffs are informed and believe and on that basis
allege BAKER routinely encouraged and promoted and directed both
Us WEEKLY staffers and freelancers to socially date professional
paparazzi photographers so that they could obtain information
for Us WEEKLY about the stories competitor magazines were
working on and going to publish.

32. On or about June 1, 2004 BAKER and MIN initiated a
plan to use an Us WEEKLY reporter to volunteer at Cedars-Sinai
Medical Center in order to surreptitiously gather confidential
information for Us WEEKLY about celebrity patients being treated
there in general as well as celebrity COURTENEY COX, who was
giving birth there at that time.

33. When informed of this decision, JILL ISHKANIAN
confronted BAKER about it and informed him she thought his ruse
was unethical and should be immediately discontinued. She
further informed BAKER his scheme to have a reporter pose as a
hospital volunteer would reflect badly on Us Weekly.

34. BAKER ordered Us WEEKLY staff and freelance contract
reporters to sift through the garbage of actor BEN AFFLECK. As
a result, Us WEEKLY obtained discarded prescription medicine
bottles for AFFLECK as well as AFFLECK’s home telephone bill.
35. BAKER demanded Us WEEKLY staffers research “what was
wrong” with AFFLECK based upon the prescription medication
bottles taken from his garbage. JILL ISHKANIAN and other Us
WEEKLY staff members vehemently objected to BAKER’s BEN AFFLECK
pill assignment based on the grounds such assignment was not
news worthy, was unethical and was reprehensible.