36. In October 2003 JILL ISHKANIAN obtained a video tape
depicting PARIS HILTON having sex with RICK SOLOMON (“Hilton Sex
Tape”). JILL ISHKANIAN was the first reporter anywhere to have
this story or possess the Hilton Sex Tape.

37. BAKER and JILL ISHKANIAN initiated a conference call
with MIN to inform her of JILL ISHKANIAN’s possession of the
Hilton Sex Tape. During this call MIN stated the Hilton Sex
Tape was not a story Us WEEKLY was going to cover. BAKER and
MIN nevertheless ordered JILL ISHKANIAN to ship the Hilton Sex
Tape to Us Weekly’s New York offices, which JILL ISHKANIAN did.

38. Us WEEKLY thereafter published the Hilton Sex Tape
story without giving credit to JILL ISHKANIAN. BAKER took
credit for breaking the Hilton Sex Tape story, which became an
international news sensation. JILL ISHKANIAN protested.

39. Defendants’ failure to give JILL ISHKANIAN credit for
the Hilton Sex Tape story was a violation of the terms of JILL
ISHKANIAN’s employment agreement, the terms and conditions of
her employment, WENNER MEDIA’s and Us WEEKLY’s policies as well
as industry standards.

40. The Hilton Sex Tape is an example of how BAKER, MIN,
JANN WENNER and WENNER MEDIA utilized the work of JILL ISHKANIAN
to gain notoriety and acclaim for themselves while
simultaneously attempting to keep credit from JILL ISHKANIAN for
her reportage.

41. On or about September 2004 JILL ISHKANIAN broke the
story about BRITNEY SPEARS’ fake wedding and prenuptial
agreement with KEVIN FEDERLINE (“Spears Faux Wedding and Pre-Nup
Story”).

42. JILL ISHKANIAN brought the Spears Faux Wedding and
Pre-Nup Story to BAKER. BAKER told JILL ISHKANIAN that story
was not something Us WEEKLY could publish for unexplained “legal
reasons”.

43. As with the Hilton Sex Tape, after rejecting JILL
ISHKANIAN’s proposed story, BAKER decided to publish the Spears
Faux Wedding and Pre-Nup Story on Us Weekly’ front cover and to
take credit for breaking it himself.

44. In accomplishing this, BAKER and an Us WEEKLY photo
editor personally contacted JILL ISHKANIAN’s confidential source
on the Spears Faux Wedding and Pre-Nup Story and negotiated a
deal with him. BAKER and MIN intentionally failed to give any
credit to JILL ISHKANIAN as the original reporter who uncovered
the Spears Faux Wedding and Pre-Nup Story. Again, JILL
ISHKANIAN protested.

45. Defendants’ failure to give JILL ISHKANIAN credit for
the Spears Faux Wedding and Pre-Nup Story was a violation of the
terms of JILL ISHKANIAN’s employment agreement, the terms and
conditions of her employment, WENNER MEDIA’s and Us WEEKLY’s
policies as well as industry standards.