THE HOSTILE WORK ENVIRONMENT AT US WEEKLY

68. On or about April 2004 BAKER held a meeting with his
staff and forced everyone in attendance to vote about whether or
not a freelance reporter had real breasts or surgically
augmented breasts.

69. On or about April 2004 Plaintiffs are informed and
believe and on that basis allege BAKER sent cell phone text
messages to NANNY which included messages stating: “I want to
have sex with you.” “I’m not attracted to my wife. Come meet me
in Laguna Beach, I’m working on my book. I need to see you.” “I
want to see you pregnant with pigtails.”

70. On or about May 21, 2004 JILL ISHKANIAN confronted
BAKER about his inappropriate behavior relating to female
employees and NANNY as detailed herein above and informed him of
her negative opinion of what she believed was his inappropriate
behavior. In response, BAKER yelled at JILL ISHKANIAN and told
her to “stay out of it”.

71. Plaintiffs are informed and believe and on that basis
allege that on or about April 2004 NANNY, upset by BAKER’s
sexual advances toward her, showed at least one Us WEEKLY
employee at the Los Angeles office BAKER’s text messages sent to
her.

72. Plaintiffs are informed and believe and on that basis
allege these text messages from BAKER to NANNY containing his
explicit sexual advances were saved by NANNY and thereafter were
viewed by staff at the Us WEEKLY offices in Los Angeles. As a
result, BAKER’s sexual advances towards the NANNY became well
known to West Coast Us WEEKLY staffers at that time.

73. Plaintiffs are informed and believe and on that basis
allege BAKER’s continued requests of NANNY to have sexual
relations with him caused strain between NANNY and her then
boyfriends who were paparazzi photographers, thus creating a
deleterious effect on Us WEEKLY’s published product.

74. BAKER routinely and repeatedly encouraged Us WEEKLY
staff to seek romantic relationships with paparazzi
photographers in order to better facilitate their ability to
gather information about celebrities. This Us WEEKLY policy was
known to, approved by and endorsed by all Defendants.

75. On or about July 2005 BAKER entered JILL ISHKANIAN’s
office, closed the door and began to cry. During this
conversation BAKER used up all of JILL ISHKANIAN’s Kleenex to
wipe his eyes and runny nose.

77. BAKER asked JILL ISHKANIAN if she would lie on his
behalf to anyone who inquired about BAKER’s sexual activities in
the Us WEEKLY office in general and also about the online media
watchdog blog story in particular. JILL ISHKANIAN refused
BAKER’s request to lie on his behalf.