46. On or about September 14, 2005 BRITNEY SPEARS gave
birth to her first baby at St. John’s Hospital. Us WEEKLY
reporters discovered this fact by the use of radio scanners they
utilized to listen to radio communications between SPEARS’
private security team.

47. Plaintiffs are informed and believe and on that basis
allege BAKER also informed Us WEEKLY staff that he wanted to
bring alcohol to them in their car while they were working so as
to celebrate their breaking such a big story.

48. On or about January 26, 2005 an Us WEEKLY editor
resigned her position to work for OK! Magazine. JANN WENNER
alleged this action violated the editor’s employment agreement.

49. Plaintiffs are informed and believe and on that basis
allege that thereafter, JANN WENNER hired a New York private
detective to investigate the editor who resigned. In connection
with that investigation, said private detective contacted JILL
ISHKANIAN and informed her he was a former FBI agent who can
“make things happen”.