62. On several different occasions JILL ISHKANIAN informed
the New York offices of Us WEEKLY about their failure to return
various items sent to Us WEEKLY for photographing for
publication. Us WEEKLY had an unwritten policy, endorsed and
practiced by MIN and BAKER, that Us WEEKLY staffers were
entitled to keep all merchandise sent to Us WEEKLY even if said
merchandise was supposed to be returned to the person, store or
entity which provided it.

63. JILL ISHKANIAN confronted BAKER about his taking a
pair of Reebok shoes sent to the office to get coverage for
their new store opening. In response, BAKER told JILL ISHKANIAN
to “Fuck off!”

64. Plaintiffs are informed and believe and on that basis
allege that as a result of JILL ISHKANIAN complaining to MIN and
BAKER about staffers taking items sent to Us Weekly, and in
direct retaliation for it, JILL ISHKANIAN was removed from her
regular “Love Lives” column without notice or explanation to
her.

65. JILL ISHKANIAN had a job performance review conducted
by BAKER on July 1, 2005. In said job performance review, BAKER
wrote of JILL ISHKANIAN: “You show great respect for the rules
of the office and function as a valuable watchdog over the other
staff in making sure others are adhering to the standards of
conduct and dedication. This contribution of yours is much
appreciated and I hope for it to continue. The dedication to
your craft is impressive.”

66. During her tenure at Us Weekly, JILL ISHKANIAN created
a celebrity address database (“Celebrity Database”). JILL
ISHKANIAN deposited into the Celebrity Database the names and
addresses of various celebrities and news sources about
celebrities which JILL ISHKANIAN obtained prior to ever working
for Us Weekly. Most of the information contained in the
Celebrity Database was contributed by JILL ISHKANIAN and was the
property of JILL ISHKANIAN prior to her working for Us WEEKLY
and after she left Us WEEKLY.

67. On October 25, 2005 JILL ISHKANIAN resigned from her
position at Us Weekly.