50. JANN WENNER, WENNER MEDIA, MIN and BAKER implemented
and encouraged company wide policies encouraging Us WEEKLY
reporters and staff to utilize their coverage of trendy shops
and other establishments to garner free clothes, meals,
sunglasses and other items of value in exchange for Us WEEKLY’s
continued favorable coverage of said shops and establishments.

51. As a result, Us WEEKLY editors, including but not
limited to BAKER and MIN, regularly and routinely used their
status and position to obtain personal wealth and property for
themselves.

52. For example, Plaintiffs are informed and believe and
on that basis allege an Us WEEKLY editor used the Us WEEKLY
FedEx account to mail samples of her own burgeoning t-shirt line
to solicit its sale at exclusive and high profile retail stores
in Los Angeles.

53. At least one of the stores to which the Us WEEKLY
editor sent samples of her burgeoning t-shirt line was regularly
and routinely featured in Us WEEKLY.

54. Plaintiffs are informed and believe and on that basis
allege this Us WEEKLY editor sent the t-shirts to the retailer
via WENNER MEDIA’s Fed Ex account to create the impression with
said retailer that they should either sell the editor’s clothing
line or not receive any more coverage in Us WEEKLY.

55. On or about March 2005 said editor began to advertise
her burgeoning t-shirt line in Us WEEKLY free of charge. At
that time, advertisers were paying approximately $35,000 for a
full page advertisement in Us WEEKLY.

56. JILL ISHKANIAN confronted BAKER about the editor’s
free t-shirt advertising Us Weekly. BAKER told JILL ISHKANIAN:
“Never talk about this again.”

57. As a further example of the Us WEEKLY policy of
utilizing their positions to obtain personal wealth and property
from third parties, on or about August 27, 2005 BAKER solicited
a prominent Los Angeles clothes retailer who was often featured
in the pages of Us WEEKLY to host BAKER’s personal book
promotion party.

58. BAKER proposed to the retailer that, in return for
hosting his book promotion party, the retailer would receive
approximately $70,000 of advertising space in Us WEEKLY at no
charge.

60. BAKER utilized Us WEEKLY interns and Us WEEKLY
staffers to work on his book promotion party project for weeks
prior to the party. Plaintiffs are informed and believe and on
that basis allege BAKER’s use of Us WEEKLY staff and advertising
space to promote his book was known to and endorsed by JANN
WENNER, WENNER MEDIA and MIN.

61. When JILL ISHKANIAN confronted BAKER and complained to
BAKER that his use of Us WEEKLY staff for his book promotion
party was jeopardizing the quality of the staff’s work, BAKER
told JILL ISHKANIAN to “stay out of it”.