SECURITY AT US WEEKLY

78. Defendant and Us WEEKLY owner JANN WENNER visited the
Los Angeles Us WEEKLY office on or about the summer of 2003.
During his visit, JANN WENNER discovered BAKER had placed a
yellow boomerang to prop open the office back door.

79. Plaintiffs are informed and believe and on that basis
allege JANN WENNER discovered the purpose of propping open the
back door of the Los Angeles office of Us WEEKLY was so that
BAKER and other Us WEEKLY staffers and visitors to Us WEEKLY
could bypass office security and enter the offices thereby.

80. Plaintiffs are informed and believe and on that basis
allege upon discovering these facts, JANN WENNER informed BAKER
the back door should never be propped open and office security
should be strictly enforced.

81. After JANN WENNER’s visit, BAKER continued to utilize
the yellow boomerang to prop open the office back door so he and
others, including visitors, could bypass office security. BAKER
was particularly fond of using this propped open door to utilize
the back office bathroom so that he would not have to walk
around to the front of the office to relieve himself, have cell
phone conversations in the hall, and let in his guests without
their going through the security screening process.

82. Plaintiffs are informed and believe and on that basis
allege after JANN WENNER’s visit, the West Coast office manager
told BAKER he was not to continue to circumvent office security
by propping open the back office door. In reaction to this,
BAKER wrote on the boomerang the words “Dawn-o-rang” with the
intent to mock and belittle the office manager’s attempt to
enforce office security.

83. Plaintiffs are informed and believe and on that basis
allege BAKER thereafter initiated a policy whereby many interns,
freelancers, and Us WEEKLY staffers were provided the computer
password for BAKER’s personal Us WEEKLY e-mail.

84. BAKER initiated a policy whereby many interns,
freelancers, and Us WEEKLY staffers were provided the computer
password for Us Weekly’s reporting box (“Reporting Box”).

85. The Us WEEKLY Reporting Box was utilized to filter
each and every story on which Us WEEKLY was working. BAKER
approved the code for accessing the Reporting Box to a four
digit code that was extremely simplistic. This password was
provided to Us WEEKLY staffers, Us WEEKLY freelancers, and
unpaid Us WEEKLY interns.

86. Us WEEKLY regularly and routinely gave Us WEEKLY
computer passwords to staff, non-staff, third parties, including
interns and freelance reporters, photographers and photo
agencies.

87. Although many of the individuals who were provided
with the Reporting Box password lacked security passes to access
the front door of the Us WEEKLY Los Angeles offices, by virtue
of their possession of the Reporting Box password they each had
access to all of Us Weekly’s reporting and computers, which they
could access remotely from anywhere in the world.

88. Plaintiff is informed and believes and on that basis
alleges an Us WEEKLY staffer told two of his superiors including
BAKER they did not think it was safe to provide computer
passwords to everyone working for or otherwise associated with
Us Weekly. Further, said staffer specifically complained to
BAKER that it was particularly unsafe from a security standpoint
to have an extremely simplistic Reporting Box password.

89. Plaintiffs are informed and believe and on that basis
allege that after registering his complaints with BAKER, the
same Us WEEKLY staffer referred to in the previous paragraph was
assigned the task by BAKER of deleting all of BAKER’s emails
from his email “in box” so that BAKER, who was out of the office
at that time, could receive messages.

90. On or about May 2004 Us Weekly provided JILL ISHKANIAN
with a password for the Us WEEKLY server as well as the Flynet
Pictures website. JILL ISHKANIAN was also provided with a
username at that time.

91. Plaintiffs are informed and believe and on that basis
allege computer passwords at Us WEEKLY were routinely provided
to reporters who were connected romantically or socially to
photographers and other competitor reporters. As a result,
these third party photographers and competitor reporters knew Us
WEEKLY computer user names and passwords and regularly and
routinely accessed Us WEEKLY computers for the purpose of
obtaining private and confidential Us WEEKLY information,
including but not limited to information about stories Us WEEKLY
was working on for future publication.

92. All of the foregoing relating to Us WEEKLY security
and lack thereof was known to all Defendants at all times
mentioned herein.