- 1 - DECLARATION OF PETER KIEFER IN SUPPORT OF D EFENDANT LOS ANGELES MAGAZINE’S SPECIAL MOTION TO S TRIKE PURSUANT TO CC P SEC. 425.16 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Gordon Rees Scully Mansukhani, LLP 101 W. Broadway, Suite 2000 San Diego, CA 92101 SUPERIOR COURT OF CALIFORNIA COUNTY OF LOS ANGELES I, Peter Kiefer, declare: 1 . I wrote the article discussing Yashar Ali that was published in Los Angeles Magazine in 2021 and that is the subject of this lawsuit. I have personal knowledge of the facts stated in this declaration. 2. All of the facts stated or implied in the article were rigorously fact checked and confirmed prior to publishing the article. I believed, and still believe, that the facts stated or implied in the article were true. I did not have, and I do not now have, doubts about the truth of any of the facts stated in the article or that I in tended to imply in the article. 3. In the course of conversations I had with Ali prior to the publication of the article, MILES D. SCULLY (SB N: 135853) mscully@grsm.com TIMOTHY K. BRANSON ( SBN: 187242) tbranson@grsm.com GABRIEL G. HEDRICK (SBN: 220649) ghedrick@grsm.com GORDON REES SCULLY M ANSUKHANI, LLP 101 W. Broadway, Suite 2000 San Diego, CA 92101 Telephone: (619) 230 - 7422 Facsimile: (619) 696 - 7124 Attorneys f or Defendant LOS ANGELES MAGAZINE , LLC YASHAR ALI , an individual, Plaintiff, vs. LOS ANGELES MAGAZINE, LLC , a California limited liability company ; and DOES 1 - 20, inclusive, Defendants. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) CASE NO. 22STCV18984 DECLARATION OF PETER KIEFER IN SUPPORT OF DE FENDANT LOS ANGELES MAGAZINE LLC ’S SPECIAL MOTION TO ST RIKE PURSUANT TO CCP SEC. 425.16 Date: Time: Dept.: Judge: Hon. Gregory Keosian Reservation ID: Complaint Filed: June 9, 2022 Trial Date: Not Set January 24, 2023 984082585326 10:00 a.m. 61 Electronically FILED by Superior Court of California, County of Los Angeles on 12/23/2022 01:54 PM Sherri R. Carter, Executive Officer/Clerk of Court, by V. Sino-Cruz,Deputy Clerk