Jonathan Steinsapir

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February 7, 2019

VIA E-MAIL AND FACSIMILE

Radar Online
American Media, Inc.
Attention: General Counsel

New York, NY 10004

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Re: Puported Radar Online Artice re “Exhumation of Michael Jackson”

Gentlepersons:

We are counsel to the Co-Executors of the Estate of Michael J. Jackson, as well as

various wholly-owned entities which own intellectual property and other intangible rights
associated with the late Michael Jackson (collectively the “Estate” or the “Jackson Estate”).

The Estate asked me to alert you to the fact that your website, Radar Online, appears
to have fallen victim to a hack by online pranksters who are posting utterly ludicrous articles
on it. In particular, we refer you to the “article” that appeared on your site at 9:30 a.m. on
February 6, 2019, entitled Michael Jackson’s Body May Be Exhumed As 11 More Sex Assault
Victims Come Forward.1 The only thing about the article that struck us as genuine—and not a
hack—was the fact that it was attributed to “Radar Staff.” No individual, of course, would
attach their personal name to such a trashy article full of obvious lies.

In the very unlikely event that this article was indeed a genuine article by “Radar
Online,” could you please ask your “source” when Mr. Jackson’s body will be exhumed? As
the successors to Mr. Jackson’s legal interests, the Estate’s representatives were surprised no
one told them about this unusual development. We see that the source is identified as “an
insider”—can you let us know what asylum he is inside?

1
https://radaronline.com/exclusives/2019/02/michael-jackson-grave-ripped-from-
crypt-sexual-assault-scandal-buried-proof/
Radar Online
February 7, 2019
Page 2

Likewise, the article refers to an “army of shell-shocked victims” with “at least 11 new
victims who claim they were molested and even raped by Jackson.” We are shocked that the
Santa Barbara District Attorney’s Office—which spent over a decade on a virtual jihad
against Jackson trying to prove that he was a molester without success, because he was not—
never found this “army of shell-shocked victims.” Perhaps your source—the “insider”—
should start working for law enforcement and finding real child molesters.

The article continues that “Radar has also learned the FBI was accused of covering up
evidence that Jackson was a sex trafficker!” It continues that “Secret files obtained by Radar
show a journalist claimed in 1993 that a starstruck FBI official ‘did not pursue the allegations
because Jackson was to receive an honor at the White House.’” The article states that Mr.
Jackson was at one time being considered for prosecution under “the White Slave Traffic
Act” yet “[d]espite the claims of witnesses who saw him smuggle a 12-year-old across
America by train, the U.S. Attorney dropped the case.” These are shocking accusations of
government misconduct indeed.

Of course, nothing in the article is true. The article is full of maliciously and provably
false statements. If you have fact-checkers—and, frankly, we find that hard to believe in light
of this article—they should be fired on the spot. (We cannot offer you legal advice, but we
believe you have good cause for terminating them.) The only “redeeming” thing we can say
about your “fact checking” here is that the assertions in your article are so absurd that the
article (perhaps) might not “reasonably be understood as describing actual facts.” Hustler
Magazine, Inc. v. Falwell, 485 U.S. 46, 57 (1988).

In closing, it is not our usual practice to tell persons in other professions how to do
their jobs, but we will make an exception here. May we suggest that you try something
different in the future and talk to real, sane, and credible sources? If you had any modicum of
credibility left, you would retract this ridiculous “article.” We hereby demand that you do so.
We understand that your business is failing, but perhaps it would be doing better if you
stopped publishing this ridiculous garbage.

One final point, and lest there be any doubt, nothing stated in this letter should be
construed to waive any of the Jackson Estate’s rights and remedies in connection with this
article—all such rights are expressly reserved.

Kindest regards,

Jonathan Steinsapir
cc: Howard Weitzman, Esq.
Bryan Freedman, Esq.
Jon Fine, Deputy General Counsel, American Media Inc.
10386.00347/620948