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UNITED STATES DISTRICT COURTSOUTHERN DISTRICT OF NEW YORK

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AULISTAR MARK, HANCHEN LU andANDREW HUDSON,Individually and on Behalf ofAII Others Similarly Situated,Plaintiffs,-against-GAWKER MEDIA LLC, and NICK DENTON,Civil Action No. I :13-cv-04347-AJNDefendants.

AFFIDAVIT OF CHARLIE JANE ANDERSCHARLIE JANE ANDERS declares, ursuant o 28 U.S.C. 51746, hat he ollowing strue and correct:1. I am of legal age and am competent o make his Declaration. havepersonal nowledge of the facts sets orth in this Declaration. r I have earned said actsto speak on behalf of Gawker Media, LLC.2. I currently am the Managing Editor of Gawker Media, LLC's( Gawker's ) website, o9.com, a daily publication hat covers science, cience iction,and he future. Previously, served as he Associate Editor and News Editor of io9.3. I personally supervised many of the nterns myself.4. Annalee Newitz (the Editor-In-Chief of io9) was n charge of acquiringthe intern applicants o interview, and I helped nterview applicants or the entertainmentsection of the blog from early 2008 until we ended he ntern program n January 2013.5. Usually there were two interns at any given time that would learn the partof the website hat covered entertainment. Sometimes here was one additional internthat earned he part of the website hat covered science, which Annalee supervised. X

Case 1:13-cv-04347-AJN Document 32 Filed 01/10/14 Page 1 of 4

Intems were only responsible or contributing o a few posts per week, which is not asignificant effort. If we did not have nterns o contribute o these posts, our employeeswould have been able to write them during their regular workday, or we would simplynot have written them at all. We would not have had to hire additional paid staff. Weinitially told interns hat we required hem o contribute en hours per week, but I wouldbe surprised f any of them put in more han ive hours per week. We encouraged hemto write as much as hey liked for us but it was not required.6. Since different nterns soent ime on different sections f the site ordifferent editors, most of them contributed emotely. Meredith Woerner, currently heEntertainment ditor of io9, has also supervised nterns. At times she had nterns comeinto the office, but I did not interact with them.7. Since he ntems mostly contributed emotely and were only required ocomplete a few hours per week, the interns contributed on their own time and had no setschedule. An individual nternship could ast up to four or six months, but often nternswould ask f they could continue nterning with us for longer.8. None of our internships were paid, and he intems understood hat t wasan unpaid position. We had one or two paid nterns at the aunch of the site, but westopped aying he next nterns hat arrived n 2009. None of the subsequent nternscomplained hat hey were not paid since hey understood hat t was an unpaid nternshipfrom the beginning. If I used any of their writing in an editorial post, hey would ofcourse eceive a byline or a shared yline.9. The training program was not a formal process. We explained herequired asks when the interns first arrived and then gave hem lots of feedback over the


hrst month or two to make sure hey were on track. For example, when interns carriedout research, hey would often come back with insufficient esults. I would tell them howthey missed mportant hings hat were necessary o make he research ruly completeenough or a story. After giving them research ips, I would send hem back o try theresearch gain.10. I also spent some of my time with io9 interns eaching hem how to bebetter writers. i would edit pieces of intern writing and ell the nterns what they neededto do differently n terms of formatting and one. When hey successfully esearched ndcontributed o articles, would give them a co-byline. We always encouraged hem o tryto pitch their own articles and o write themselves. The goal was o teach hem enough sothat hey would be able o curate a site hemselves.1 . This type of supervision ontrasts with my supervision f regularemployees. The full-time employees now how to curate a site, and how to pitch,research, rite, and edit posts. I do not have ime to hold their hands. With interns, hold their hands more. Since we usually only hired experienced riters as employees,the ntems equired a significantly arger amount of guidance rom me as heir supervisor.Some nterns were better han others. but thev all required me to take more ime withthem han would with a full-time writer.12. There was never a promise of a full-time ob at Gawker at the end of anyinternship.13. I gave many references or both graduate chool and ob applications.
